Paul L. and Doris J. Triemstra, et al. - Page 22

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               We hold that petitioners' failure to look beyond the                   
          Northeast offering memorandum and the representations by two                
          insiders of Northeast was unreasonable and not in keeping with              
          the standard of the ordinarily prudent person.  See LaVerne v.              
          Commissioner, 94 T.C. 637 (1990); Marine v. Commissioner, 92 T.C.           
          958 (1989).  We find no merit in petitioners' argument about                
          their supposed faith in the representations in the offering                 
          memorandum allegedly based on the concept that Federal and State            
          securities laws discourage false and misleading statements.                 
          Petitioners' educational backgrounds and professional experience            
          belie such feigned naivety.  Likewise, since petitioners were               
          experienced attorneys familiar with offering memoranda, we are              
          unconvinced by their contention that they reasonably disregarded            
          the cautionary language and risk alerts because they believed               
          such admonitions were inserted for the benefit of the promoter.             
          On its face, the cautionary language is directed to the investor.           
          Petitioners have presented no reason for us to doubt that the               
          cautionary language means what it says.                                     
               Petitioners' reliance on Heasley v. Commissioner, 902 F.2d             
          380 (5th Cir. 1990), revg. T.C. Memo. 1988-408, and Ewing v.                
          Commissioner, 91 T.C. 396 (1988), affd. without published opinion           
          940 F.2d 1534 (9th Cir. 1991), is misplaced.  The facts in the              
          Heasley case are distinctly different from the facts of these               
          cases.  In the Heasley case, the taxpayers were not educated                
          beyond high school and had limited investment experience, while             




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