Robert P. Neumann and Sally A. Neumann - Page 8

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          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 meaningful                        





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