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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 of
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