- 68 -- 68 -
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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