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proceeds were not properly characterized as long-term capital
gain. In particular, in March 1980, Henry exercised the right to
acquire 4,000 shares of IMED common stock for $13 per share.
Later, Henry sold these shares of stock on October 16, 1980, for
$190,000. Thus, petitioners sold the shares for $47.50 per
share, some $34.50 more than the option price. Moreover, Henry's
education and work experience enabled him to value stock and
growth projections for companies. Consequently, Henry knew or
should have known that the section 83(b) election, which he
signed in September of 1979, was invalid insofar as it stated
that the fair market value of the 1979 options was zero.
Also, petitioners cannot rely on Hendrickson's statements
made concerning the election nor the IMED form letter obtained on
September 14, 1979, to negate additions to tax for negligence
attributable to their 1982 return. In general, petitioners had
an obligation to independently verify their own proper income tax
liability. In other words, petitioners failed to ask pertinent
questions or even make a cursory investigation beyond the
information provided to them concerning the IMED stock options.
See LaVerne v. Commissioner, 94 T.C. 637, 652-653 (1990), affd.
without published opinion sub nom. Cowles v. Commissioner, 949
F.2d 401 (10th Cir. 1991), affd. without published opinion 956
F.2d 274 (9th Cir. 1992); see generally sec. 1.6661-6(b), Income
Tax Regs. Moreover, the duty of filing accurate tax returns
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