Daniel C. Greer and Winnie L. Greer - Page 11

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              Mr. Greer showed the offering memorandum to his tax return              
         preparer and tax adviser to confirm the tax computations Madison             
         represented would result from his investment prior to purchasing a           
         limited partnership unit.  The tax adviser and return preparer Mr.           
         Greer contacted was John Artis, a certified public accountant with           
         the accounting firm of Smith, Goolsby, Artis, & Reams in Ashland,            
         Kentucky (the accounting firm).  The accounting firm had prepared            
         petitioners’ income tax returns for approximately 10 years before            
         1982.   Mr. Artis did not read the entire offering memorandum, but           
         based upon his conversations with Mr. Greer, he understood that              
         the tax benefits associated with the Madison interest exceeded the           
         dollars invested.  Because of this understanding, Mr. Artis told             
         Mr. Greer that Madison was “fairly aggressive” from a tax                    
         standpoint.  Mr. Artis was not asked by Mr. Greer to provide a               
         written tax opinion about the merits of the tax treatment                    
         represented in the Madison offering memorandum; rather, Mr. Greer            
         asked him to confirm the amount of the tax benefits petitioners              
         would claim on their tax return for 1982, if Mr. Greer purchased             
         the limited partnership interest.  Mr. Artis told Mr. Greer the              
         result on the 1982 return he computed would be in accord with the            
         benefits Mr. Greer expected.                                                 
              Petitioners’ capital contribution was limited to their                  
         $50,000 investment in Madison because Mr. Greer purchased a 5.5-             
         percent limited partnership unit in Madison that was not subject             

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