- 599 - transactions. It was not shown that any of IRA's other advisers had knowledge or had been apprised of all the relevant facts. See Collins v. Commissioner, 857 F.2d 1383 (9th Cir. 1988), affg. Dister v. Commissioner, T.C. Memo. 1987-217; Zmuda v. Commissioner, 731 F.2d 1417 (9th Cir. 1984). Although reasonable reliance on the advice of professionals may be a defense to negligence, IRA did not show that the reliance in the instant cases was reasonable. See Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991). Consequently, we sustain respondent's determinations that IRA is liable for the addition to tax for negligence or intentional disregard of rules or regulations under section 6653(a) for 1980, 1983, 1984, 1985, and 1986 on the underpayments from the equipment leasing transaction adjustments. These section 6653(a) additions include (1) an addition to tax under section 6653(a) for 1980, (2) an addition to tax under section 6653(a)(1) and (2) for 1983, 1984, and 1985, and (3) an addition to tax under section 6653(a)(1)(A) and (B) for 1986. We also conclude that IRA failed to establish that it acted reasonably and in good faith in claiming the disallowed 1985 capital losses (Issue 25) from its purported sales of various assets to Kanter and Holding Co. As discussed previously, IRA failed to show that section 267 was inapplicable or that the sales were bona fide. Consequently, we sustain respondent'sPage: Previous 587 588 589 590 591 592 593 594 595 596 597 598 599 600 601 602 603 604 605 606 Next
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