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limited partner opinion was addressed to the limited partners
rather than the general partner, contained no statement that the
limited partners could not rely on the opinion, included a
section on the impact of the investment on State and local taxes,
and was signed by Boylan & Evans. Petitioner believed Boylan &
Evans worked for Madison at the time it issued the limited
partner opinion. Petitioner reviewed the limited partner opinion
before he filed his 1982 tax return, compared it to the general
partner opinion, and relied on its assessment of the risks
described in the POM.
On or around January 12, 1983, petitioner received a letter
from Mr. Roberts confirming the close of the partnership on
December 21, 1982, and transmitting an executed copy of
petitioner’s subscription agreement.
Petitioner’s Monitoring of the Madison Investment
On or around March 9, 1983, petitioner received a Financial
Planning Report (report) and corresponding cover letter prepared
by HG&C. Petitioner reviewed the cover letter and report. The
report informed petitioner that he had invested $850,000 in
“limited partnerships with tax advantages” and, among other
things, the report promoted HGSC and participation in “tax-
sheltered investments”. The report further informed petitioner
that if he invested in a tax sheltered investment,
[HGSC] will receive a commission on the sale. Also,
because [HGSC] is an affiliate of our organization, we
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