Mark Friedman - Page 53

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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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