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(1976). In reaching our decision, the Commissioner’s treatment
of other taxpayers is generally considered irrelevant. Id.
Petitioners next argue that Bauman invested in ERL only
after extensive discussions with other partners in his law firm.
They also contend that certain professional financial advisers
were consulted by various partners of Bauman’s law firm and that
such consultations contributed to Bauman’s decision to invest in
ERL. We reject this argument as self-serving; it is not
supported by the facts of the record.
Petitioners further argue that Bauman relied heavily on the
contents of the offering materials, which petitioners contend
were prepared by various experts. But those responsible for
preparing the contents of the offering materials were not
disinterested advisers, nor were they shown to be in fact
experts. Moreover, Bauman was not an unsophisticated investor.
We find his testimony regarding his alleged good faith reliance
questionable. At best, the information contained in the offering
materials was speculative conjecture. The offering materials
were “long on conclusions, but short on reasoning”, and we are
skeptical that an intelligent, educated person such as Bauman
could in good faith rely thereon in hope of earning a profit
independent of tax considerations. See Lieber v. Commissioner,
T.C. Memo. 1993-424.
Reliance on the advice of professionals may serve to defeat
a finding of negligence, but we are not convinced that
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