- 25 - 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 businessPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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