Bruce and Lois Zenkel, et al. - Page 58

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          United States, 72 AFTR 2d 93-6443, 93-2 USTC par. 50,585 (D.                
          Ariz. 1993).  This Court declined to sustain the negligence                 
          additions to tax in the Reile and Davis cases for reasons                   
          inapposite to the facts herein.  In the Davis case, the taxpayers           
          reasonably relied upon a "trusted and long-term adviser" who was            
          independent of the investment venture, and the offering materials           
          reviewed by the taxpayers did not reflect that the principals in            
          the venture lacked experience in the pertinent line of business.            
          In the Reile case, the taxpayers, a married couple, had only one            
          year of college between them and characterized themselves as                
          financial "dummies."  In contrast to those cases, petitioners               
          herein are well educated, sophisticated, and successful                     
          professional and business people.  Their reliance on Becker,                
          Steele, and/or Sprague with respect to the essential valuation              
          issue and the economic viability and bona fides of the                      
          Partnership transactions was misplaced and inconsistent with                
          Becker's disclosure of the limitations of his investigation.                
          Although Blount did not talk to Becker, Sprague related to Blount           
          the particulars of Becker's investigation.  In addition, the                
          offering memoranda disclosed that the Partnerships had no prior             
          operating history and that the general partner had no prior                 
          experience in marketing recycling or similar equipment.                     
          Accordingly, petitioners' reliance on the Reile and Davis cases             
          is misplaced.                                                               






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