Sheldon M. Sisson - Page 8

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          without such expertise.  Tippin v. Commissioner, 104 T.C. 518,              
          534 (1995).  Petitioner in this case specialized in tax shelter             
          planning and litigation and had over 20 years of experience.  In            
          addition, he had litigated tax shelter cases for the IRS and                
          possessed extensive knowledge of tax shelters similar to those at           
          issue in this case.                                                         
               Petitioner makes two arguments in support of his contention            
          that he was reasonable in taking the deductions.  First,                    
          petitioner argues that we should conclude he was not negligent,             
          because he researched and wrote an opinion letter analyzing the             
          transactions.  Petitioner concluded in his opinion letter that              
          the deductions relating to the transactions would be permissible            
          under the Code.  The transactions involved the circular transfer            
          of funds among related entities (both domestic and foreign) for             
          the sole purpose of generating tax deductions.  In Wolverine,               
          Ltd. v. Commissioner, supra, we concluded that the transactions             
          lacked economic substance.  At the time petitioner claimed the              
          deductions, case law uniformly indicated that transactions                  
          lacking economic substance would not be respected for tax                   
          purposes.  See, e.g., Gregory v. Helvering, 293 U.S. 465, 469               
          (1935); Bercy Indus., Inc. v. Commissioner, 640 F.2d 1058, 1062             
          (9th Cir. 1981), revg. 70 T.C. 29 (1978).  Petitioner has failed            
          to establish that he, as an experienced tax practitioner, was               
          reasonable in claiming a distributive share of the deductions               






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