Daniel C. Greer and Winnie L. Greer - Page 2

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                    Held: P-husband’s actions regarding the                           
               partnership interest were negligent, and R was not                     
               required to advise Ps regarding R’s investigation of                   
               the promoter.  Therefore, the additions to tax under                   
               sec. 6653(a)(1) and (2), I.R.C., are sustained.                        
                    Held, further, the remittance which was repaid by                 
               R is excluded from R’s computations of the addition to                 
               tax under sec. 6653(a)(2), I.R.C.                                      
                    Held further, the addition to tax under sec. 6659,                
               I.R.C., is sustained.                                                  

               Joy L. Hall, Martin J. Horwitz, and John A. Freeman, for               
          petitioner Daniel C. Greer                                                  
               Kenton Ball, for petitioner Winnie L. Greer.                           
               Aubrey C. Brown and Denise A. Diloreto, for respondent.                

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               GOEKE, Judge:  The issues in this case concern respondent’s            
          determinations that petitioners are liable for additions to tax             
          under sections 6653(a)(1) and (2), and 66591 on the deficiencies            
          in tax resulting from the disallowance of a partnership loss and            
          related tax credits claimed on petitioners’ 1982 joint Federal              
          income tax return and carried back to petitioners’ joint Federal            
          income tax returns for 1979 through 1981.  These tax benefits               

               1    Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              

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