- 53 -
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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