Bevel M. and Patricia N. Hoffpauir - Page 6

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               Petitioners received a $60.48 distribution related to the              
          accounting software a few months after making the investment.               
          They were told the payment was based on sales of 32 units.                  
          3.   Petitioners’ Other Investments                                         
               Petitioners bought silver bullion from a company called                
          Monex through Marinelli and Dollar at Century soon after buying             
          an interest in the accounting program.  Petitioners also invested           
          in a Denver company started by a friend of petitioner called                
          Pyrodisc, which produced a newly invented product similar to a              
          Frisbee.  Petitioners did not own stock except in SDSI and                  
          Pyrodisc.  Petitioners did not earn a profit from their silver or           
          Pyrodisc investments, and they lost the money they had invested             
          in them.                                                                    
          4.   Petitioners' Tax Returns                                               
               Before 1983, Stanton's Accounting and Tax Service prepared             
          petitioners' and SDSI's tax returns.  Dollar prepared                       
          petitioners' 1983 tax return.  He was not a C.P.A.  Petitioner              
          reviewed the 1983 return before it was filed.  Petitioners did              
          not have a financial or tax adviser or attorney on retainer in              
          1983.  Petitioners have prepared their own tax returns since 1984           
          or 1985.                                                                    
               Petitioners reported a $1,131 loss and claimed a $9,375                
          investment tax credit (of which they used $1,774) on their 1983             
          tax return.  Petitioners carried back unused investment tax                 





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