- 9 -
Indeed, according to his testimony, petitioner had only a vague,
and in fact incorrect, understanding of the investment, namely,
that it had something to do with "drilling". The failure to make
even minimal inquiries regarding the investment is a strong
indication of negligence. See Goldman v. Commissioner, supra at
407-408; Lucas v. Commissioner, T.C. Memo. 1995-341. Moreover,
there is no evidence that petitioner monitored his investment or
the activities of Ridge Energy after investing.
Petitioner points to his age and lack of sophistication as
an excuse for failing to make an effort to ascertain Mr. Coscia's
expertise or the merits of the investment being proposed. We
disagree. Petitioner held a college degree and was successfully
operating his own business at the time.
We have previously sustained respondent's determination
imposing additions to tax for negligence and substantial
understatement relating to a loss and investment tax credit
claimed with respect to another 1983 Ridge Energy partner in Buck
v. Commissioner, T.C. Memo. 1997-191. Likewise, we have upheld
respondent's negligence determinations in numerous cases
involving taxpayers who invested in energy management systems
leased from Saxon Energy and argued that their reliance on
professional advice precluded the negligence addition. See
Turner v. Commissioner, T.C. Memo. 1995-363; Levine v.
Commissioner, T.C. Memo. 1995-362; Maminga v. Commissioner, T.C.
Memo. 1995-361; Lucas v. Commissioner, T.C. Memo. 1995-341;
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