- 8 -8 advice of independent advisers, we believe that in the instant case such reliance does not rise to the level necessary to overcome such a finding. Although it appears that Hansen and Minger were not investors in the Alamo partnerships, petitioners' reliance on their professional advice was not reasonable. There is no evidence to indicate that either Hansen or Minger had any expertise in the music recording industry. Moreover, petitioner testified that both Hansen and Minger rendered their opinions based solely on the prospectus and Nunez's tax opinion. Neither of them sought any independent evaluations or appraisals. We believe it incredible that petitioners would argue that such reliance upon the cursory review by advisers regarding matters outside their field of expertise constitutes the actions of a reasonable and ordinarily prudent investor. We have stated before that investors cannot escape the negligence penalty by relying on the advice of persons who are not professional investment counselors. Pasternak v. Commissioner, 990 F.2d 893, 903 (6th Cir. 1993), affg. Donahue v. Commissioner, T.C. Memo. 1991-181; Rybak v. Commissioner, 91 T.C. 524, 565 (1988). In sum, we believe that a reasonable investor would have done more to protect his or her investment than what petitioners did in the instant case. We find petitioners' actions, in failing to conduct anything approaching a meaningfulPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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