- 21 -                                         
          in the offering memorandum, especially the discussions of high              
          writeoffs and risk of audit, should have alerted a prudent and              
          reasonable investor to the questionable nature of the promised              
          deductions and credits.  See Collins v. Commissioner, 857 F.2d              
          1383, 1386 (9th Cir. 1988), affg. Dister v. Commissioner, T.C.              
          Memo. 1987-217; Sacks v. Commissioner, T.C. Memo. 1994-217, affd.           
          82 F.3d 918 (9th Cir. 1996).  A reasonably prudent person would             
          not conclude without substantial investigation that the                     
          Government was providing tax benefits so disproportionate to the            
          taxpayers' investment of their own capital.                                 
               2.  Petitioner's Purported Reliance on Advisers                        
               Petitioner contends that he reasonably relied upon Marcus              
          and Hefter as qualified advisers on this matter.                            
               A taxpayer may avoid liability for the additions to tax                
          under section 6653(a)(1) and (2) if he or she reasonably relied             
          on competent professional advice.  United States v. Boyle, 469              
          U.S. 241, 250-251 (1985); 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.  Freytag v. Commissioner, supra.  For reliance on               
          professional advice to excuse a taxpayer from the negligence                
          additions to tax, the taxpayer must show that the professional              
          had the expertise and knowledge of the pertinent facts to provide           
          informed advice on the subject matter.  David v. Commissioner, 43           
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