Jeffrey I. and Roberta H. Stone - Page 18

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          section 6653(a) for 1980 and 6653(a)(1) and (2) for 1981.  Each             
          of petitioners has the burden of proving that respondent's                  
          determinations of these additions to tax are erroneous.  Rule               
          142(a); Luman v. Commissioner, 79 T.C. 846, 860-861 (1982).                 
               Section 6653(a) for 1980 and section 6653(a)(1) for 1981               
          impose an addition to tax equal to 5 percent of the underpayment            
          if any part of an underpayment of tax is due to negligence or               
          intentional disregard of rules or regulations.  In cases                    
          involving negligence for 1981, an additional amount is added to             
          the tax under section 6653(a)(2); such amount is equal to 50                
          percent of the interest payable with respect to the portion of              
          the underpayment attributable to negligence.  Negligence is                 
          defined as the failure to exercise the due care that a reasonable           
          and ordinarily prudent person would employ under the                        
          circumstances.  Neely v. Commissioner, 85 T.C. 934, 947 (1985).             
          The question is whether a particular taxpayer's actions in                  
          connection with the transactions were reasonable in light of his            
          experience and the nature of the investment or business.  See               
          Henry Schwartz Corp. v. Commissioner, 60 T.C. 728, 740 (1973).              
               Petitioners in these consolidated cases contend that they              
          were reasonable in claiming deductions and credits with respect             
          to the Partnerships.  Petitioners each allege that they                     
          reasonably relied upon the advice of qualified advisers, and that           
          they reasonably expected an economic profit in light of the so-             
          called oil crisis in the United States during 1981.  In each                

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