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petitioner’s testimony was vague; he merely recalled having asked
Freasier whether the investment “would fly”. We believe this
inquiry was directed to whether the purported tax deductions “would
fly”, not whether the economics of the investment “would fly”. We
are not convinced that Freasier possessed sufficient knowledge
about the nontax aspects of the partnership to give petitioner
competent advice.
Petitioner compares his case to Mollen v. United States, 72
AFTR 2d 93-6443, 93-2 USTC par. 50,585 (D. Ariz. 1993), in which a
medical doctor who invested in one of the partnerships described in
Charlton v. Commissioner, T.C. Memo. 1990-402, avoided the
imposition of negligence penalties because of reliance on advisers.
Mollen is not binding herein.
In summary, petitioner failed to prove that any part of the
underpayment of his 1982 and 1983 taxes was due to reasonable
cause. To the contrary, we hold that the entire underpayment of
taxes for both years was the result of petitioner’s negligence.
Accordingly, petitioner is liable for additions to tax under
section 6653(a)(1) and (2) for 1982 and 1983.
Issue 2. Valuation Overstatement
The second issue is whether petitioner is liable for additions
to tax under section 6659. That section imposes an addition to tax
if an underpayment of tax of $1,000 or more is attributable to a
valuation overstatement. Sec. 6659(a), (d). A valuation
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