Dolores J. Myers - Page 19




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          selling and managing interests in Jojoba, yet they did not                  
          endeavor to independently examine or monitor this investment or             
          otherwise seek independent advice regarding the tax consequences            
          of their investment.  It is unreasonable to make investment                 
          decisions based solely on the advice of an interested party.                
          Hill v. Commissioner, T.C. Memo. 1993-454.  The Myerses neglected           
          to seek any independent advice although the offeree                         
          questionnaire, subscription agreement, and PPM repeatedly urged             
          petitioners to do so and were replete with warnings of the risks            
          associated with the investment and its tax consequences.                    
               Petitioners have not demonstrated that the Myerses exercised           
          reasonable care in deciding whether to invest in Jojoba and how             
          to report the tax consequences of that investment or that they              
          reasonably relied on Mr. Matsuda’s advice regarding the Jojoba              
          investment.  Accordingly, we hold that petitioners are liable for           
          the additions to tax for negligence under section 6653(a) with              
          respect to the underpayments for the taxable years before us.               
          III. Conclusion                                                             
               We have carefully considered all remaining arguments made by           
          petitioners for contrary holdings and, to the extent not                    
          discussed, conclude they are irrelevant or without merit.                   











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