- 20 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011