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At trial, petitioner stated that, in 1983, at the
recruitment meeting for the Barrister partnerships' independent
sales representatives, the presentation by the partnership
promoters originally did not pass petitioner's "sniff test".
Petitioner was skeptical as to whether the Barrister partnerships
had economic substance. However, after speaking with numerous
certified public accountants (C.P.A.'s), attorneys, and other tax
professionals, petitioner became convinced that the partnerships
were not shams. He decided to become an independent sales
representative and, eventually, an investor in Series 162.
Petitioner stated that, in making this decision, he did not focus
on the cash flow projections of the partnerships because the
C.P.A.'s made these computations for petitioner, and he accepted
their responses.
Prior to petitioner's involvement in the Barrister
partnerships, he had never been involved in book publishing.
Petitioner has a college degree in business and, for
approximately 25 years, was a salesman. The fact that petitioner
did not have knowledge of the book publishing industry did not
concern him because he felt that Cohen, as well as the services
contractors, had a great deal of experience in the industry.
However, petitioner did not consult with these individuals or
anyone else in the publishing business about the economic
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