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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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