Charles A. Greene and Christine J. Greene - Page 3

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          Cir. 1995); Fagan v. City of Vineland, 22 F.3d 1283, 1290 (3d               
          Cir. 1994); Sanders v. Sullivan, 900 F.2d 601, 605 (2d Cir.                 
          1990).  The issues remaining for decision are:  (1) Whether any             
          part of an underpayment of income taxes for 1983 or 1984 is due             
          to negligence or intentional disregard of rules or regulations;             
          and if so, (2) whether the portion of the underpayment due to               
          negligence is eliminated or reduced by petitioners' filing of an            
          amended return reporting and paying additional income tax for the           
          taxable year 1983.                                                          
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  At the time the petition             
          in this case was filed, petitioners were residing in High Point,            
          North Carolina.                                                             
                                  FINDINGS OF FACT                                    
               During the years 1983 and 1984, Charles A. Greene                      
          (petitioner) was a limited partner in a partnership known as Mid            
          Continent Drilling Associates II (Mid Continent or the                      
          partnership).  The additions to tax in this case relate to                  
          petitioner’s investment in Mid Continent.                                   
          Petitioners' Work and Business History                                      
               Petitioner Christine Greene is a high school guidance                  

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