- 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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