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Finally, petitioner’s attempts to monitor and salvage his
Madison investment do not demonstrate that petitioner made his
investment in Madison primarily to make a profit. His attempts
are consistent with a concern about losing his $75,000
investment but do not disprove a concern about tax benefits.
d. Conclusion
When petitioner filed his 1982 return, he had some
investment experience and the knowledge and experience
associated with a successful career as a chemical engineer.
However, petitioner has failed to establish that he reasonably
investigated or analyzed Madison, or that he reasonably relied
on competent and informed professional advice in deciding to
invest in Madison and in claiming Madison’s tax benefits on his
1982 return. We hold, therefore, that petitioner is liable for
the section 6653(a)(1) and (2) additions to tax for negligence.
B. Section 6659
Under section 6659, a graduated addition to tax is imposed
if an individual has an underpayment of at least $1,000 that is
attributable to a valuation overstatement. Sec. 6659(a), (d).
A valuation overstatement exists if the value of any property,
or the adjusted basis of any property, claimed on any return
exceeds 150 percent of the amount determined to be the correct
amount of such valuation or adjusted basis. Sec. 6659(c)(1).
If the claimed valuation exceeds 250 percent of the correct
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