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Petitioners failed to exercise due care in claiming the
deductions and tax credits relating to their investment in
Sunbelt. We find that they did not reasonably rely upon Storey
or in good faith investigate the aspect of the investment that
generated the "attractive" tax benefits--the value of the
Sentinel recycler. Therefore, we hold that petitioners are
liable for the negligence additions to tax under the provisions
of section 6653(a) for 1979 and 1980 and section 6653(a)(1) and
(a)(2) for 1981 and 1982.
To reflect the foregoing, and to ensure that the
Stipulation of Settled Issues is properly taken into account,
Decision will be
entered under Rule 155.
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