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the Plastics Recycling cases before us.) The Carmagnola reports
were a part of the record considered by this Court and reviewed
by the Sixth Circuit Court of Appeals in Provizer v.
Commissioner, T.C. Memo. 1992-177, where we held the taxpayers
negligent. Consistent therewith, we find in these consolidated
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 cite a number of cases in support of their
position, but primarily rely on Durrett v. Commissioner, 71 F.3d
515 (5th Cir. 1996), affg. in part and revg. in part T.C. Memo.
1994-179; Chamberlain v. Commissioner, 66 F.3d 729 (5th Cir.
1995), affg. in part and revg. in part T.C. Memo. 1994-228;
Wright v. Commissioner, T.C. Memo. 1994-288; Wood v.
Commissioner, T.C. Memo. 1991-205; Davis v. Commissioner, T.C.
Memo. 1989-607; and Mollen v. United States, 72 AFTR 2d 93-6443,
93-2 USTC par. 50,585 (D. Ariz. 1993).
This Court dismissed the negligence additions to tax in the
Wright, Wood, and Davis cases for reasons inapposite to the facts
herein. In the Wright case, the taxpayers were unsophisticated
investors with little or no experience in financial matters;
nothing in their lives had given them the experience they needed
to manage their money or to recognize the importance or meaning
of the warning signs inherent in the investment at issue. In
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