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profit objective where the only appraisals relied upon by
taxpayer-investors were made by a tax shelter promoter).
Petitioners did not investigate Dollar’s professional
qualifications. Cf. Allen v. Commissioner, 925 F.2d 348, 354
(9th Cir. 1991), affg. 92 T.C. 1 (1989).
Petitioners used an independent tax preparation service to
prepare their returns before 1983. In 1983, they relied on
someone who had a financial interest in the shelter in which they
were investing to prepare their return. Unlike the Heasleys,
petitioners obtained tax advice only from the shelter promoter.
See Klieger v. Commissioner, T.C. Memo. 1992-734 (taxpayers were
negligent because they relied unreasonably on advice of shelter
promoters). To avoid the addition to tax for negligence on the
ground of reasonable reliance, petitioners must show that they
reasonably relied on the advice of a qualified and independent
tax professional, not the tax shelter promoter. Id.; see Estate
of Strober v. Commissioner, T.C. Memo. 1992-350.
Petitioners made no real effort to monitor their investment
or conduct any meaningful review of the computer software in
which they had bought an interest. Heasley v. Commissioner,
supra (taxpayers who actively monitored their investment and made
inquiries of servicing agent were not negligent). Petitioners'
receipt of a $60.48 distribution is not significant because it
is only 1-1/4 percent of petitioners' payment; they would have to
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