Stuart A. and Harriet J. Gollin, et al. - Page 68

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          advice not reasonable where expert lacks knowledge of business in           
          which taxpayers invested); Goldman v. Commissioner, 39 F.3d at              
          408 (same).  Accordingly, we shall not relieve petitioners of the           
          negligence additions to tax based upon the Court of Appeals for             
          the Fifth Circuit's decisions in the Durrett and Chamberlain                
          cases.15                                                                    
               5.  Conclusion as to Negligence                                        
               Under the circumstances of these cases, petitioners failed             
          to exercise due care in claiming large deductions and tax credits           
          with respect to the Partnerships on their Federal income tax                
          returns.  We hold that petitioners did not reasonably rely upon             
          the offering memoranda, their purported advisers, or in good                
          faith investigate the underlying viability, financial structure,            
          and economics of the Partnership transactions.  We are                      
          unconvinced by the claim of these experienced and highly                    
          sophisticated, able, and successful professionals that they                 
          reasonably failed to inquire about their investments and simply             
          relied on the offering circulars and their purported advisers,              
          despite warnings in the offering circulars and explanations by              
          Becker about the limitations of his investigation.  In each case            

          15   Other cases cited by petitioners are inapplicable and                  
          distinguishable for the following general, nonexclusive reasons:            
          (1) They involve far less sophisticated, if not unsophisticated,            
          taxpayers; (2) the reasonableness of the respective taxpayers'              
          reliance on expert advice was established in those cases on                 
          grounds that do not exist here; and (3) the advice given was                
          within the adviser's area of expertise.                                     





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