- 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;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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