- 6 - Petitioner's investment in Republic represents almost 40 percent of her reported taxable income for 1982. She did not have an attorney or accountant examine the investment. Petitioner relied on Russell's verbal explanation of the partnership and did not read the offering memorandum. Russell told her that he had investigated "the partnership", and petitioner "felt" that he had thoroughly investigated the investment. Although she was told in 1985 that "they were having success in placing these machines," petitioner apparently took no action to monitor her investment. It was in 1985 that petitioner last spoke to Russell who filed for bankruptcy under Chapter 7 in that year. In January of 1995 petitioner for the first time received notice that the investment tax credits from Republic were not proper. On April 7, 1995, she paid the assessed taxes and interest due as a result of respondent's disallowance of the Republic deductions and credits. In notices of deficiency for affected items issued on February 17, 1995, respondent determined that the underpayments of taxes for the years 1979 through 1982 are subject to the negligence additions of section 6653(a)(1) and (2), and that the tax underpayments are attributable to a valuation overstatement as described in section 6659.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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