Joe E. Henry and Carolyn J.Henry - Page 20

                                       - 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