- 22 - his experience and the nature of the investment or business. See Henry Schwartz Corp. v. Commissioner, 60 T.C. 728, 740 (1973). When considering the negligence addition to tax, we evaluate the particular facts of each case, judging the relative sophistication of the taxpayers, as well as the manner in which they approached their investment. McPike v. Commissioner, T.C. Memo. 1996-46. Compare Spears v. Commissioner, T.C. Memo. 1996- 341 with Zidanich v. Commissioner, T.C. Memo. 1995-382. Petitioners contend that they were reasonable in claiming deductions and credits with respect to Northeast. They maintain that petitioner "conducted a good faith investigation of the Northeast transaction and did not merely rely on the offering memorandum or other materials supplied by the investment vendor." Petitioners further assert that they reasonably expected to make a profit from Northeast because plastic is an oil derivative and the United States was experiencing a so-called oil crisis during the latter 1970's and early 1980's. Petitioner's educational background and professional experience should have enabled him to make a reasonable and informed assessment of the Sentinel EPE recycler and the Northeast transaction. His own testimony is that he reviewed the offering memorandum repeatedly; visited PI and viewed a demonstration of the machine; spoke with members of WMDI, Roberts, Bambara, and Celanese personnel; and analyzed the economics of the transaction. However, the record in this case,Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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