- 18 - 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 eachPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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