Philippe and Nadine Grelsamer - Page 58

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          good faith investigate the underlying viability, financial                  
          structure, and economics of the Partnership transactions.  We are           
          unconvinced by the claim of these experienced engineers and                 
          highly sophisticated, able, and successful businessmen that they            
          reasonably failed to inquire about their investments and simply             
          relied on the offering circulars and on Green, their tax return             
          preparers, and ultimately Becker, despite warnings in the                   
          offering circulars and explanations by Becker about the                     
          limitations of his investigation.  In each case, these taxpayers            
          knew or should have known better.  We hold, upon consideration of           
          the entire records, that petitioners are liable for the                     
          negligence additions to tax under the provisions of section                 
          6653(a) for the taxable years at issue.  Respondent is sustained            
          on this issue.                                                              
          B.  Section 6659--Valuation Overstatement                                   
               Respondent determined that petitioners are each liable for             
          the section 6659 addition to tax on the portion of their                    
          respective underpayments attributable to valuation overstatement.           
          Petitioners have the burden of proving that respondent's                    
          determinations of these section 6659 additions to tax are                   
          erroneous.  Rule 142(a); Luman v. Commissioner, 79 T.C. at 860-             
          861.                                                                        
               A graduated addition to tax is imposed when an individual              
          has an underpayment of tax that equals or exceeds $1,000 and "is            






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