Andrew J. and Marilyn Welch - Page 8




                                        - 8 -                                         
          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.                               

























Page:  Previous  1  2  3  4  5  6  7  8  

Last modified: May 25, 2011