Paul L. and Doris J. Triemstra, et al. - Page 17

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          securities lawyer.  Kravitz also knew that Roberts and Grant were           
          both insiders in the Northeast transaction.  Roberts was a 9-               
          percent shareholder in F & G in addition to being the general               
          partner in Northeast.  Grant was the 100-percent owner of ECI.              
          The Northeast offering memorandum stated that both Roberts and              
          Grant were promoters.  While Roberts waived his commission for              
          petitioners, he still received a general partners' fee and                  
          percentage interest.  This fee and the percentage interest were             
          unambiguously disclosed in the Northeast offering memorandum.               
          Similarly, Grant's position as sole shareholder of the "seller"             
          (ECI) and the profitable nature of that position were disclosed             
          in the offering memorandum.                                                 
               We find that petitioners' reliance on Roberts and Grant, two           
          promoters of Northeast, was not reasonable, not in good faith,              
          nor based upon full disclosure.  See Vojticek v. Commissioner,              
          T.C. Memo. 1995-444, to the effect that advice from such persons            
          "is better classified as sales promotion."  The record does not             
          show that either Grant or Roberts possessed any special                     
          qualifications or professional skills in the recycling or                   
          plastics industries.  While Kravitz did, in his capacity as an              
          attorney, deal with Roberts or Grant in three real estate                   
          ventures, the record does not convince us that these prior                  
          dealings, strictly limited to the real estate area in which                 
          Kravitz was experienced, provided any reasonable basis for his              
          apparent blind faith in Roberts and Grant in plunging into a tax-           

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