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$4,503 to $67,156. Clearly these were substantial transactions
requiring careful investigation under the Anderson case. Unlike
the adviser in Anderson, neither Maxfield nor petitioners
thoroughly investigated or educated themselves in the industry of
the proposed investment. In view of the substantial basis
claimed for the interest of each petitioner in the machinery (in
each case a substantial amount greater than the cash invested),
from which the investment credits stemmed, plainly something more
was required. Accordingly, we consider petitioners' reliance on
the Anderson case inappropriate.
Petitioners' reliance on the Durrett and Chamberlain cases
is also misplaced. In those cases, the Court of Appeals for the
Fifth Circuit reversed this Court's imposition of the negligence
additions to tax in two nonplastics recycling cases. The
taxpayers in the Durrett and Chamberlain cases were among
thousands who invested in the First Western tax shelter program
involving alleged straddle transactions of forward contracts. In
the Durrett and Chamberlain cases, the Court of Appeals for the
Fifth Circuit concluded that the taxpayers reasonably relied upon
professional advice concerning tax matters. In other First
Western cases, however, the Courts of Appeals have affirmed
decisions of this Court imposing negligence additions to tax.
See Foulds v. Commissioner, T.C. Memo. 1994-489 (the well-
educated taxpayer failed to establish the substance of advice,
and the purported adviser lacked tax expertise), affd. without
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