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Utah I, supra, the test case, and by our opinions in Christensen
v. Commissioner, T.C. Memo. 2001-185, Serfustini v. Commissioner,
T.C. Memo. 2001-183, and Nilsen v. Commissioner, T.C. Memo. 2001-
163, in each of which we upheld negligence additions to tax
relating to investments in Blythe II. No credible evidence in
this case provides any legitimacy to petitioners’ investment in
the Blythe II partnership.
In light of the above, for each year in issue petitioners
are liable for the negligence addition to tax under section
6653(a), (a)(1), and (a)(2).
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011