Lawrence R. Roberson - Page 17

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          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.                               














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