Lawrence R. Roberson - Page 13

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          (1989); Rybak v. Commissioner, 91 T.C. 524, 565 (1988).                     
          Additionally, when an investment has such obviously suspect tax             
          claims as to put a reasonable taxpayer under a duty of inquiry,             
          a good faith investigation of the underlying viability,                     
          financial structure, and economics of the investment is                     
          required.  LaVerne v. Commissioner, supra at 652-653; Horn v.               
          Commissioner, 90 T.C. 908, 942 (1988).                                      
               In the instant case, petitioner claims that he relied on               
          several professional advisers with respect to his investment in             
          Southampton.  Petitioner learned about the Southampton                      
          investment program from Cunningham, a financial adviser who                 
          encouraged petitioner to invest in a master recording lease.                
          Petitioner was aware, however, that Cunningham received a                   
          commission if petitioner decided to invest in Southampton and               
          that Cunningham was serving as a salesman rather than an                    
          independent adviser acting solely on petitioner's behalf.                   
          Petitioner also argues that he relied on statements made by                 
          Parnell, an enrolled agent who had reviewed the Southampton                 
          promotional booklet.  There is no evidence in the record that               
          Parnell relied on anything other than the materials furnished by            
          Southampton or that either Parnell or Cunningham had otherwise              
          investigated the bona fides of the master recording investment.             
          Similarly, there has been no showing that the accountants who               
          prepared petitioner's 1982 and 1983 tax returns evaluated the               





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