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returns without making any attempt to learn about the Partnership
transactions. Petitioner acknowledged that he found the tax
benefits unbelievable. Yet even after Becker expressly warned
that such tax benefits were contingent on the economics of the
transactions, petitioner made no effort to learn about the
Partnership transactions. He ignored Becker's urging that he
should read the offering memoranda. His claim that he did not
know offering materials were available is not credible and casts
doubt on the veracity of the rest of his testimony. We hold that
petitioner did not reasonably rely upon Becker, or in good faith
investigate the underlying viability, financial structure, and
economics of the Partnership transactions. Upon consideration of
the entire record, we hold that petitioner Allan J. Becker is
liable for the negligence additions to tax under section 6653 for
the taxable years at issue. Respondent is sustained on this
issue.
C. Section 6659--Valuation Overstatement
In two notices of deficiency, respondent determined that
petitioner is liable for the section 6659 addition to tax on the
portion of his 1981 and 1982 underpayments attributable to
valuation overstatement. Petitioner has the burden of proving
that respondent's determinations of the section 6659 additions to
tax are erroneous. Rule 142(a); Luman v. Commissioner, 79 T.C.
at 860-861. In her answer, respondent asserted an increased
amount due under section 6659 for 1982. Respondent has the
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