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respect to one of the partners therein.11 The Court of Appeals
for the Ninth Circuit reversed our imposition of the negligence
additions to tax. Petitioners point out that the taxpayer in
that case relied in part upon a tax opinion contained in the
offering materials.
11 Osterhout v. Commissioner, T.C. Memo. 1993-251, affd. in
part and revd. in part without published opinion sub nom. Balboa
Energy Fund 1981 v. Commissioner, 85 F.3d 634 (9th Cir. 1996),
involved a group of consolidated cases. The parties therein
agreed to be bound by the Court's opinion regarding the
application of the additions to tax under sec. 6653(a), inter
alia. Accordingly, although the Court's analysis focused on one
taxpayer, the additions to tax were sustained with respect to all
of the taxpayers.
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