Marco Deplano - Page 9

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          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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