- 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