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program promoted by Lukensow and offered by GD&L. Lukensow
provided petitioner with promotional materials for the container
leasing program. These materials included a question and answer
memorandum regarding the program, a favorable letter from an
attorney, and a prospectus of the container leasing program.
Petitioner reviewed and relied on these documents. Although
petitioner did not completely understand the documents, his basic
understanding of these materials was that an investment in the
program would substantially reduce his Federal income tax
liability.
Petitioner relied on the following passages from the
question and answer memorandum:
Q. Aren't container leasing tax shelters an industry-
wide scam?
A. Yes, we too have heard of such schemes. The only
answer to that is that we have been and are now
honorable and legitimate and plan to be around for a
long time. It is not the form of the investment that
is important - it is the expertise that goes into
making it successful. All scams will mimic legitimate
projects and are actually trading on the good name of
the ones that have achieved success.
* * * * * * *
Q. How do we know that your firm can, and will, do
what you say?
A. * * * Our chief counsel, Alex Laurins, is an
attorney, formerly with the IRS and with years of
experience in the tax field. Our staff of attorneys
has reviewed this program at every step and is now
exercising the same meticulous preparatory work on our
forthcoming mining tax shelter. * * *
In addition to this excerpt, petitioner relied on the
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