Paul L. and Doris J. Triemstra, et al. - Page 6

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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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