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testified that he typically relied on his own judgment for
investments under $100,000; his investment in Hyannis was in the
amount of $25,000. When asked who he relied upon in making the
Hyannis investment, petitioner replied, "My own judgment."
Petitioner attempts to distinguish himself from the
taxpayers in Provizer v. Commissioner, T.C. Memo. 1992-177, by
arguing that he was not an educated, sophisticated investor and
attorney seeking to shelter income. However, while petitioner
did not receive a college degree, he did receive some higher
education and he was anything but unsophisticated in business and
investing. Petitioner's entrepreneurial spirit, energy, and
business acumen led to the creation and prosperity of various
apparel businesses. Petitioner's business ventures culminated in
the founding of NBO, a business which became so successful
petitioner was able to sell half of it for $25,000,000 in 1988.
In addition, from 1980 to the time of trial, petitioner invested
approximately $16,000,000 in upwards of 70 ventures. In light of
petitioner's remarkable and impressive business success and
extensive investing activity, the fact that he never received a
college degree does not persuade us that he was an
unsophisticated businessman or investor.
Similarly, we are not persuaded that petitioner lacked
interest in the tax benefits generated by Hyannis. According to
the Hyannis offering memorandum, the projected benefits for each
$50,000 investor were investment tax credits in 1981 of $79,200
plus deductions in 1981 of $42,491. In the first year of the
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