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regulations. In cases involving negligence, an additional amount
is added to the tax under section 6653(a)(2); such amount is
equal to 50 percent of the interest payable with respect to the
portion of the underpayment attributable to negligence.
Negligence is defined as the failure to exercise the due care
that a reasonable and ordinarily prudent person would employ
under the circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985). The question is whether a particular taxpayer's actions
in connection with the transactions were reasonable in light of
his experience and the nature of the investment or business. See
Henry Schwartz Corp. v. Commissioner, 60 T.C. 728, 740 (1973).
Petitioners in these consolidated cases contend that they
were reasonable in claiming deductions and credits with respect
to the Partnerships. To support their contentions, they allege,
in general terms, that they relied upon the advice of qualified
advisers, and that they expected an economic profit in light of
the so-called oil crisis in the United States during 1981. In
each of the cases before us, petitioners' investigation of the
Partnership transactions and the Sentinel EPE recyclers was
limited to conversations with Bachmann and Greene, respectively,
and in varying degrees, a review of the offering memoranda.7
7 It is unclear from the records to what extent Abramson
influenced any of petitioners' decisions to invest in the
Partnerships. While Abramson participated in the purported
investigation of the Partnerships, petitioners' testimony
indicates that their reliance was placed predominantly on
Bachmann and Greene. Abramson's generally vague and indefinite
testimony in these cases supports the conclusion that he was not
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