Philippe and Nadine Grelsamer - Page 53

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          rely solely upon his preliminary, ill-founded valuation                     
          estimates.  Carmagnola has not been called to testify in any of             
          the Plastics Recycling cases before us.  See Bresler v.                     
          Commissioner, 65 T.C. at 188; Pollack v. Commissioner, 47 T.C. at           
          108; Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. at               
          1165.  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 are not                  
          relieved of the negligence additions to tax based on the                    
          preliminary reports prepared by Carmagnola.                                 
               Petitioners' reliance on Reile v. Commissioner, T.C. Memo.             
          1992-488, and Davis v. Commissioner, T.C. Memo. 1989-607, is                
          misplaced.  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                






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