Charles A. Greene and Christine J. Greene - Page 20

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          founding and management of his own business.  We would hesitate             
          to call him an "unsophisticated" investor.                                  
               Petitioner, however, attempted at trial to demonstrate to              
          the Court his lack of sophistication.  He testified both on                 
          direct and cross-examination that because the partnership was               
          assigned a tax shelter number by the IRS, he thought the IRS had            
          "approved" the shelter.  He never asked Corman if this were true,           
          testifying that he believed it as a "matter of trust".  Yet,                
          petitioner identified a Mid Continent subscription agreement that           
          he introduced into evidence.  He testified that he reviewed the             
          agreement before deciding to invest in Mid Continent.  A                    
          paragraph in the agreement cautions the reader that no "Federal             
          governmental authority has made any finding or determination                
          relating to the fairness for public investment" in the                      
          partnership and that there has been and will be no Federal                  
          recommendation or endorsement of the partnership.                           
               Petitioner testified that he invested in the partnership               
          relying on the advice of Corman and other partnership investors.            
          It appears from the record that Corman was paid to perform                  
          accounting services for Classic Gallery, not to give investment             
          advice to petitioners.  Petitioner's testimony was also rather              
          vague as to just what specific investment advice Corman gave him            
          about the partnership other than that it was a "good" investment.           

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