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          regarding such benefits.                                                    
          G.   Ultimate Finding Regarding Petitioner’s Motivation                     
               Petitioner invested in Whitman principally because the                 
          investment offered immediate tax benefits in excess of his                  
          investment.                                                                 
          H.   Events Leading to the Filing of Petitioners’ 1982 Return               
               Early in 1983, petitioner received from Sam Winer a Schedule           
          K-1 (Partner’s Share of Income, Credits, Deductions, etc.) for              
          the Whitman partnership for the taxable year 1982.  The Schedule            
          K-1 disclosed that petitioner’s share of Whitman’s loss for 1982            
          was $11,852 and that petitioner’s share of the partnership’s                
          basis in the 4 EPS recyclers for investment credit purposes was             
          $116,200.  Although these amounts were actually consistent with             
          the tax benefits promised in the offering memorandum, petitioner            
          was sensitive to their magnitude and mindful of the fact that               
          they might flag his investment as a tax shelter.  Petitioner was            
          also uncertain how to convert his share of the partnership’s                
          basis in the recyclers into the regular investment tax credit and           
          the energy tax credit on his individual return.  Accordingly,               
          petitioner contacted a certified public accountant for                      
          assistance.8                                                                
               The accountant that petitioner contacted was unable to help            
               8  Petitioner did not contact his brother because petitioner           
          did not disclose personal financial information to him.                     
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