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investment alone, petitioners claimed an operating loss in the
amount of $20,326 and investment tax and business energy credits
related to Hyannis totaling $39,604, while petitioners'
investment in Hyannis was $25,000. The direct reductions in
petitioners' Federal income tax, from just the tax credits,
equaled 158 percent of their cash investment. Given petitioners'
combined gross income of $363,705 for 1981, we find petitioner's
alleged lack of interest in the tax benefits generated by Hyannis
unconvincing.
Also, we are unpersuaded by petitioners' efforts to
trivialize this case. The argument is that because of
petitioner's heavy business responsibilities, his great wealth,
and his substantial income, he could not be expected to spend
much time on a mere $25,000 investment. In petitioner's words
"because of the comparatively minimal amount, it did not get the
diligence or the discretion that probably should have been given
to it". In our view, despite petitioner's numerous and
significant responsibilities, he is required to exercise due care
with respect to his Federal income taxes. Obviously, there is no
rule permitting wealthy people to be negligent with respect to
claims of tax benefits but imposing penalties on those with less
income who claim the same benefits. Moreover, the record here
demonstrates that the tax benefits of the Hyannis deal were not
trivial to petitioner. While petitioner paid $25,000 for his
share of Hyannis, on his 1981 tax return he indicated ownership
of investment property of $198,016 related to Hyannis, and that
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