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order for reliance on professional advice to excuse a taxpayer
from the negligence additions to tax, the reliance must be
reasonable, in good faith, and based upon full disclosure. Id.;
see Weis v. Commissioner, 94 T.C. 473, 487 (1990); Ewing v.
Commissioner, 91 T.C. 396, 423-424 (1988), affd. without
published opinion 940 F.2d 1534 (9th Cir. 1991); Pritchett v.
Commissioner, 63 T.C. 149, 174-175 (1974).
In 1981, Wilson began to play professional football for the
National Football League. He was 22 years old at that time.
Wilson acquired his interest in EI in 1981 upon the recommenda-
tion of his sports agent and attorney, Efron. Wilson met Efron
through a mutual friend, Wayne Paulson. He met Paulson while he
was at the University of Illinois. He transferred there in 1980,
so in 1981, Paulson and Efron were recent acquaintances of
Wilson. Wilson was represented by other counsel in his
litigation with the Big Ten concerning his football eligibility.
Efron represented Wilson as agent and attorney with respect to
Wilson's initial contract to play professional football, and
Efron arranged for his substantial fee to be withheld from
Wilson's compensation and paid directly to Efron. Wilson had no
significant savings and had made no investments prior to his
purchase of 1-1/2 units of EI, with a face value of $150,000. In
connection with this very large investment, Efron provided Wilson
a copy of the offering memorandum and discussed it with him, and
also provided a copy of the revised offering memorandum, which
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