Carl J.D. Bauman and Margaret A. Bauman - Page 29

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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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