Charles A. Greene and Christine J. Greene - Page 9

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          would retain more than or less than 50 percent of the obligation            
          to Mitchell.                                                                
               On or about June 21, 1983, petitioner and Fields came to               
          terms memorialized in an assignment of interest document.                   
          Petitioner purchased Fields' interest in Mid Continent by paying            
          the final $10,000 capital call plus $600 interest and by assuming           
          half of the $120,000 obligation to Mitchell.                                
          Preparation of the 1983 and 1984 Returns                                    
               Corman subsequently prepared petitioners' 1983 Federal                 
          income tax return.  Petitioners claimed an ordinary loss of                 
          $46,007 and an investment credit of $190 reflecting their share             
          of Mid Continent losses and credits based upon the Schedule K-1             
          provided to them by the partnership.4  Corman also prepared                 
          petitioners' 1984 return, on which they claimed a Mid Continent             
          partnership loss of $1,633.5                                                
               The record does not reflect that petitioner made any further           
          inquiry about or investigation into the operations of Mid                   
          Continent, even after he received notification in 1985 that the             
          partnership was suing its accountants.  Eventually, in early 1986           

               4In addition, petitioners reported partnership losses from             
          "Hotel Associates of High Point" and GeoVest B, as well as                  
          partnership gains from GeoVest A and "Greene Whiteside Co".                 
               5In addition, petitioners reported partnership gains from              
          "Greene Whiteside Co" and GeoVest A, and partnership losses from            
          GeoVest B, "Hotel Associates of High Point", "1600 Market Street            
          Associates", "Elm Street Associates I", and "Ambassador Real                
          Estate Investors L.P."                                                      

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