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uneducated so-called blue-collar workers in Heasley, petitioners
were essentially college educated and relatively wealthy young
men. Aside from their own abilities to read and consider the
proposed investment in EI, petitioners had the resources to
employ competent independent advisers and had been fully warned
that they should do so. Unlike the taxpayers in Heasley,
petitioners here chose to pay little attention to their
investments and to ignore the admonitions in the offering
circular that they should consult with capable independent
advisers. We consider petitioners' arguments with respect to the
Heasley case inapplicable to the circumstances here.
From the record in these cases, we conclude that respondent
has satisfied her burden of proving negligence in the Wilson case
for 1981 and in the Sorey case for 1978 and 1979, and that Sorey
has failed to satisfy his burden of proof as to respondent's
determination of negligence for 1981. We hold that petitioner
Sorey is liable for the negligence addition to tax for 1978,
1979, and 1981, and that petitioner Wilson is liable for such
addition to tax for negligence for 1981.
Issue 4. Sec. 6659 Valuation Overstatement
Respondent determined that Sorey was liable for the
additions to tax for valuation overstatement under section 6659
on the underpayments of his 1978, 1979, and 1981 Federal income
taxes attributable to the investment tax credits and business
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