- 17 -
financial and profit analysis, and had previous investment
experience. The evidence in this case is that petitioner
anticipated benefits primarily from tax savings. Petitioner has
failed to provide evidence of serious efforts to monitor the
Southampton investment or reliable evidence of any profit
objective independent of tax savings. We consider petitioner's
argument with respect to the Heasley case inapplicable.
Under the circumstances of this case, we find that
petitioner's actions were not reasonable and prudent and that
the underpayments attributable to the Southampton claims were
due to negligence. Accordingly, the additions to tax under
sections 6653(a) and 6653(a)(1) are sustained in full and the
additions to tax under section 6653(a)(2) are sustained as to
the underpayments due to the Southampton investment.
To reflect the foregoing and the concessions of the
parties,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011