- 40 - ventures, including another limited partnership, Efron Investors (EI), which in turn invested in Clearwater, the partnership considered in Provizer v. Commissioner, T.C. Memo. 1992-177. Efron did not inform Mrs. Steinberg of the investments in EI and Clearwater, but simply told his sister that her AMBI investments were "doing fine". She did not learn of AMBI's investments in EI and Clearwater until a few months before trial in the deficiency proceedings arising out of those investments. In contrast, petitioner invested in the Partnerships of his own volition. Petitioner was not kept in the dark by Becker; instead, Becker provided petitioner with the offering materials, explained the transaction and its risks to petitioner, and related the extent of his investigation to petitioner. In the Steinberg case, the taxpayers turned over management of Mrs. Steinberg's inherited assets to her brother, and he made the investment decisions in question. In the present case, Becker brought an investment to his brother's attention, but petitioner made his own investment decisions. The facts and circumstances of petitioner's case are distinctly different from the Steinberg case and we accordingly consider it inapplicable. Under the circumstances of this case, petitioner failed to exercise due care in claiming large deductions and tax credits with respect to the Partnerships on his Federal income tax returns. It was not reasonable for him to claim such disproportionately large tax benefits on his Federal income taxPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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