Seymour and Phyllis C. Bronson - Page 2




                                        - 2 -                                         
               Taxable Year               Additions to Tax                            
               Docket No.       Ending        Sec. 6653(a)(1)      Sec. 6653(a)(2)    
          11377-00     Feb. 29, 1984         $186                   *                 
               11378-00     Dec. 31, 1983          256                   *            
               11383-00     Dec. 31, 1983          184                   *            
               * 50% of the interest due on deficiencies of $3,712, $5,117,           
               and $3,672, respectively.                                              
          Unless otherwise indicated, section references are to the                   
          Internal Revenue Code in effect for the years in issue.                     
               The issue for decision is whether petitioners are liable for           
          each of the additions to tax determined by respondent.2                     
                                   Background                                         
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and those attached exhibits which were             
          admitted into evidence are incorporated herein by this reference.           
          On the date the petitions were filed in these cases, petitioners            
          all resided in New Jersey.                                                  
               Petitioners each invested in a venture known as Arid Land              
          Research Partners (“Arid Land” or “the partnership”) in December            
          1983.  They all became involved with the partnership through Paul           
          Trimboli, an accountant and financial planner.  Prior to the time           


          2In each of the petitions, petitioners argued that (1) the                  
          notice of deficiency was issued “beyond the Statute of                      
          Limitations”; (2) the notice “is invalid due to the fact that the           
          Commissioner failed to make a determination” after an examination           
          of facts particular to petitioners’ case; and (3) the                       
          Commissioner failed to allow petitioners “their appeal rights               
          within the Internal Revenue Service”.  Petitioners concede the              
          first issue.  Petitioners did not address the remaining issues in           
          their briefs, and we therefore consider them to have been                   
          abandoned and we need not address them here.                                




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