Paul L. and Doris J. Triemstra, et al. - Page 24

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               In the Ewing case, the taxpayers' reliance on a legal                  
          opinion letter included in an offering memorandum was considered            
          reasonable because several of the taxpayers had known and                   
          successfully dealt with the author of the opinion for over 10               
          years.  With respect to these cases, however, nothing in the                
          record indicates that any of petitioners knew the authors of the            
          draft opinion letter included in the Northeast offering                     
          memorandum.  Instead, only one of petitioners had from one to               
          three business dealings in real estate matters with the general             
          partner of the venture over a 3-year period preceding the                   
          investment.  Accordingly, we consider petitioners' arguments with           
          respect to the Ewing case inapplicable.                                     
               We conclude that petitioners Triemstra, Cohn, and Kravitz              
          were negligent in claiming the deductions and credits with                  
          respect to Bellvine's investment in Northeast on their respective           
          1981 Federal income tax returns.  We hold, upon consideration of            
          the entire record in docket Nos. 14254-89, 17923-89, and 18126-             
          89, that petitioners Triemstra, Cohn, and Kravitz are liable for            
          the respective negligence additions to tax under the provisions             
          of section 6653(a)(1) and (2) for 1981.                                     

                                             Decisions will be entered                
                                        for respondent.                               








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