- 16 - (1985); Flowers v. Commissioner, 80 T.C. 914 (1983); Steerman v. Commissioner, T.C. Memo. 1993-447. In his capacity as attorney, Kravitz dealt with Roberts or Grant in three real estate ventures during the period 1978 to 1981. Roberts was the general partner in the first venture in 1978. With respect to the latter two ventures, Kravitz could not recall at trial whether Roberts or Grant was the general partner; he knew only that it was one or the other. Kravitz testified that each of the real estate ventures closed without incident; he found the offering materials for each venture to be appropriate and correct with respect to the real estate aspects of the transaction. Cohn testified that the significant feature to him in any offering was the performance and reputation of the general partner. Triemstra testified that among the factors that induced him to invest in Northeast was his reliance on Kravitz' "investigation" and prior dealings with Roberts, and the Government's supposed encouragement of this type of investment. There is no indication in the record that Cohn or Triemstra ever had any contact with Roberts or Grant. They knew only what Kravitz told them, and relied upon his impressions of Roberts and Grant. Kravitz had no indication that either Roberts or Grant had any background in plastics or plastics recycling. Kravitz knew that Roberts' background was in banking and that Grant was aPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011