Jeffrey I. and Roberta H. Stone - Page 19

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          case, petitioners' investigation of the Partnership transactions            
          and the Sentinel EPE recyclers was essentially limited to                   
          conversations with Tomasetti, Frabotta, or Omohundro, in addition           
          to a review of the respective offering memoranda.  Petitioners              
          argue that such investigation insulates them from the negligence            
          additions to tax.                                                           
               Under some circumstances a taxpayer may avoid liability for            
          the additions to tax under section 6653(a) if reasonable reliance           
          on a competent professional adviser is shown.  Freytag v.                   
          Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011 (5th             
          Cir. 1990), affd. 501 U.S. 868 (1991).  Reliance on professional            
          advice, standing alone, is not an absolute defense to negligence,           
          but rather a factor to be considered.  Id.  In order for reliance           
          on professional advice to excuse a taxpayer from the negligence             
          additions to tax, the reliance must be reasonable, in good faith,           
          and based upon full disclosure.  Id.; see Weis v. Commissioner,             
          94 T.C. 473, 487 (1990); Ewing v. Commissioner, 91 T.C. 396, 423-           
          424 (1988), affd. without published opinion 940 F.2d 1534 (9th              
          Cir. 1991); Pritchett v. Commissioner, 63 T.C. 149, 174-175                 
          (1974).                                                                     
               Reliance on representations by insiders, promoters, or                 
          offering materials has been held an inadequate defense to                   
          negligence.  LaVerne v. Commissioner, 94 T.C. 637, 652-653                  
          (1990), affd. without published opinion 956 F.2d 274 (9th Cir.              
          1992), affd. without published opinion sub nom. Cowles v.                   




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