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The following interests were all acquired during 1981.
Bellvine acquired a 2.605250-percent limited partnership interest
in Northeast. Triemstra acquired a 26.668-percent interest in
Bellvine for $6,000. Kravitz acquired a 20-percent interest in
Bellvine for $4,500. Cohn acquired a 26.667-percent interest in
Bellvine for $6,000. As a result of the passthrough from
Northeast and Bellvine, petitioners claimed the following
operating losses and credits:
Investment Business
Petitioner Operating Loss Tax Credit Energy Credit
Triemstra $5,424 $5,654 $5,654
Cohn 5,424 5,654 5,654
Kravitz 4,068 4,241 4,241
Respondent disallowed petitioners' claimed deductions and credits
related to Bellvine's investment in Northeast.
Petitioners are all well-educated, practicing attorneys with
experience in business and investing. Kravitz received a B.A.
degree with a major in political science from Miami University in
Oxford, Ohio, in 1965. In 1968, he received a J.D. degree from
the University of Michigan Law School. Kravitz developed a
specialty in real estate law. At the time of trial, Kravitz was
a partner in a firm having approximately 240 attorneys.
In 1965 Triemstra received a B.A. degree from Calvin College
with a double major in mathematics and economics. From 1965 to
1970, Triemstra worked for the Chrysler Corporation (Chrysler).
At Chrysler he received training in finance, worked as a budget
analyst, and then worked at the corporate staff level as a credit
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