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cases are distinctly different from the Rousseau case.
Accordingly, we do not find petitioners' arguments with respect
to the Rousseau case applicable.
Under the circumstances of these cases, petitioners failed
to exercise due care in claiming large deductions and tax credits
with respect to the Partnerships on their respective Federal
income tax returns. Petitioners claim that they relied blindly
upon their accountants, one of whom, Bachmann, they uniformly
describe as a "financial genius". Bachmann is deceased, so we
are unable to inquire whether he would claim full credit for what
Reimann describes as "this wonderful advice" to invest in the
Partnerships. Abramson, the primary tax partner at Bachmann,
Schwartz, plainly made only a cursory investigation of the
transaction and was not a central figure in these investments.
Greene, a Bachmann, Schwartz partner who presented the deal to
Brodie, described it as a 4 to 1 tax shelter on which the firm
received a 10-percent commission. Petitioners described
themselves as innocents who simply followed the advice of their
accountants, whose instructions they would not even presume to
question. But the record indicates that petitioners were
educated, experienced, successful, and prosperous businessmen
capable of making their own decisions. Certainly the accountants
who testified indicated that interests in the Plastics Recycling
partnership were offered only to clients with income available
for high risk tax shelter deals which the firm made available and
on which it received a commission. Petitioners invested what
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