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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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