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matters outside of his field of expertise or with respect to
facts which he does not verify.
During 1984, Mr. Booker worked as an agent for Encore,
selling its tax shelters at a commission rate of 20 percent of
receipts from the sales of leases. Booker v. Commissioner, T.C.
Memo. 1996-261. During the latter part of 1984, Mr. Booker
issued three newsletters directed to his master recording lease
clients entitled DERWYN J. BOOKER, TAX ADVANTAGED INVESTMENT
COUNSELING. Id. Mr. Booker received commissions from Encore in
the amount of $11,010 in 1984 and in the amount of $2,976 in 1985
with respect to his 1984 master lease sales. Id. As stated
earlier, reliance on representations by insiders or promoters is
an inadequate defense to negligence. Reliance on professional
advice must be objectively reasonable. Chamberlain v.
Commissioner, supra at 732; Goldman v. Commissioner, 39 F.3d 402
(2d Cir. 1994), affg. T.C. Memo. 1993-480. Taxpayers may not
rely on someone with an inherent conflict of interest. Goldman
v. Commissioner, supra at 408. Additionally, taxpayers must be
able to show that the adviser reached his or her decisions
independently. See Leonhart v. Commissioner, 414 F.2d 749 (4th
Cir. 1969), affg. T.C. Memo. 1968-98. As an agent for Encore,
Mr. Booker had an inherent conflict of interest, as a result of
which petitioners can in no way show that Mr. Booker reached his
decisions independently when advising them. We find that any
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