- 24 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011