- 15 - 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 thePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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