- 32 -
claimed. Cf. Hull v. Commissioner, T.C. Memo. 1991-582. Under
these circumstances, petitioner's alleged reliance on his
accountant does not relieve petitioner of liability for the
additions to tax for negligence.
C. Concern for the Environment
Finally, petitioner directs our attention to his interest in
recycling and his desire to conserve natural resources. At
trial, petitioner described in detail his efforts to recycle.
For instance, petitioner pointed out:
As a child of the great depression, * * * I firmly
believed in eliminating waste, recycling and protecting
valuable and diminishing natural resources. For
example, I have used the reverse side of incoming mail
and of my old manuscripts for years. I reuse incoming
manila envelops and packaging. I shut off lights,
heat, water, doors and windows that are not being used.
We have no reason to doubt petitioner's testimony in this
regard. Yet, we fail to see how petitioner's concerns regarding
the environment make his investments in two partnerships, both of
which were designed to shelter income from taxation and produce
other tax benefits, any more reasonable. Although petitioner's
concern for the environment may have provided some motivation to
consider the Plastics Recycling leasing programs, petitioner
should have thereafter reasonably investigated his prospective
investments. As already noted, independent investigation would
have revealed the true nature of the Sentinel recycling programs
as economic shams.
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