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solely upon his preliminary, ill-founded valuation estimates.
Carmagnola has not been called to testify in any of the Plastics
Recycling cases before us. The Carmagnola reports were a part of
the record considered by this Court and reviewed by the Sixth
Circuit Court of Appeals in the Provizer case, where we held the
taxpayers negligent. Consistent therewith, we find in these
cases, as we have found previously, that the reports prepared by
Carmagnola are unreliable and of no consequence. Petitioners
Gollin and Fishbach are not relieved of the negligence additions
to tax based on the preliminary reports prepared by Carmagnola.
Petitioners cite a number of cases in support of their
positions, but primarily rely on Durrett v. Commissioner, 71 F.3d
515 (5th Cir. 1996), affg. in part and revg. in part T.C. Memo.
1994-179; Chamberlain v. Commissioner, 66 F.3d 729 (5th Cir.
1995), affg. in part and revg. in part T.C. Memo. 1994-228;
Climenhage v. Commissioner, T.C. Memo. 1993-223; Reile v.
Commissioner, T.C. Memo. 1992-488; Davis v. Commissioner, T.C.
Memo. 1989-607; Chellappan v. Commissioner, T.C. Memo. 1988-208;
Mollen v. United States, 72 AFTR 2d 93-6443, 93-2 USTC par.
50,585 (D. Ariz. 1993).
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
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