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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 tax
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