- 38 -
petitioners reported a combined tax liability of $6,511 on
$413,821 of income over 7 taxable years--based solely upon the
advice of the individuals promoting the tax shelter. Our
conclusion is reinforced by the fact that petitioners received
multiple warnings from respondent, including one as late as
February 1992, warnings that petitioners ignored. We find that
petitioners were negligent with respect to entering the Hoyt
investment, and that they were negligent with respect to claiming
the DSBS 87-C loss on their return.
To reflect the foregoing,
Decision will be entered
for respondent.
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