Paul L. and Doris J. Triemstra, et al. - Page 16

                                       - 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                  
               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           
               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 a                

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