Charles A. Greene and Christine J. Greene - Page 6

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          Partnership Investments                                                     
               One of the investments Corman recommended was in "GeoVest".            
          Petitioner "understood" that the GeoVest investments were oil and           
          gas partnerships.  Reported on petitioners' 1981 and 1982 Federal           
          income tax returns, prepared by Corman, were partnership losses             
          from investments in "GeoVest Drilling Fund Ltd 1981-A" and                  
          "GeoVest Drilling Fund Ltd 1981-B" (GeoVest).3                              
               In the middle of 1983, Corman recommended to petitioner a              
          second investment in an oil and gas partnership, the Mid                    
          Continent partnership.  Corman told petitioner that he had a                
          client, William R. Fields (Fields), who had fallen on "hard                 
          times" and was unable to meet his cash investment obligation to             
          the partnership.  Fields had invested in the partnership in 1981.           
          He was required to make the third of three yearly $10,000 cash              
          capital contributions in 1983.  Corman told petitioner that this            
          was an opportunity for him to get into the partnership at a                 
          reduced investment amount.  Corman said that the Mid Continent              
          investment was "similar" to GeoVest, "had potential for return",            
          and looked like it would be a "good investment".                            

               3Petitioners also reported partnership income of $4,585 each           
          from the "Green Lindsay Co" for 1981, and in 1982 partnership               
          income of $2,529 each from the "Green Whiteside Co" and a                   
          partnership loss of $305 from "Hofel [sic] Associates of H. Pt.".           
          The record contains no other description of these particular                

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