- 53 - This Court declined to sustain the negligence additions to tax in the Reile and Davis cases for reasons inapposite to the facts herein. In the Davis case, the taxpayers reasonably relied upon a "trusted and long-term adviser" who was independent of the investment venture, and the offering materials reviewed by the taxpayers did not reflect that the principals in the venture lacked experience in the pertinent line of business. In the Reile case, the taxpayers, a married couple, had only 1 year of college between them and characterized themselves as financial "dummies." In contrast to those cases, petitioners herein are well-educated and experienced professionals. Friedman is a corporate and Federal securities lawyer intimately familiar with public and private placements, while Alter is an entertainment and labor lawyer who also assists a number of his clients in financial matters. Feinstein and the participating partners at Shea & Gould were colleagues contemplating a similar investment, not long-term advisers to petitioners. In addition, the offering memoranda warned that the Partnerships had no prior operating history and that the general partner had no prior experience in marketing recycling or similar equipment. Accordingly, petitioners' reliance on the Reile and Davis cases is misplaced. In Mollen v. United States, supra, the taxpayer was a medical doctor who specialized in diabetes and who, on behalf ofPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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