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unreliable and of no consequence. Petitioners are not relieved
of the negligence additions to tax based on the preliminary
reports prepared by Carmagnola.
Petitioners submitted into the records of their cases a
group of reports or updates as evidence that they monitored their
investments in the Partnerships. A computer printout dated May
7, 1982, indicated that each of Empire's seven recyclers had been
shipped to various end-users. Subsequent computer printouts,
dated August 20 and September 30, 1982, indicated that only four
machines were running and, contrary to the earlier printout, one
machine had not been shipped. In a letter to Roberts dated
February 18, 1983, Bambara explained that "market prices for
polyethylene resin have remained relatively low" and "operations
of the machines * * * have not been profitable." Roberts
forwarded this letter to the limited partners approximately 2 �
months later on May 9, 1983. Also, a review of the accounting
procedures relating to the recycling operations conducted by a
certified public accounting firm is among the documents submitted
into the records in these cases by petitioners.
These documents do not convince us that petitioners closely
monitored their investments in the Partnerships. Roberts
forwarded the August 10, 1982 computer printout to petitioners on
August 25, 1982, several weeks before Foam closed. It indicated
that no recycled material had been collected from three of the
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