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that he should have understood HG’s motivation in suggesting the
transaction to him. In addition, the offering memorandum made
clear the commissions that would be paid to HG, thus indicating
their interest in selling the Madison transaction. Mr. Greer was
also astute enough to know the difference between a sales broker
and a tax expert.
Petitioners also argue that they should be relieved of the
additions to tax because respondent failed to advise them that Mr.
Roberts was under investigation in late 1982 and 1983.
Petitioners admit this is a novel argument. We find no support
for this legal position, and we note that Mr. Greer read a news
article in August 1983 which explained that Mr. Roberts had agreed
to a settlement with the Department of Justice “in federal court”
which imposed upon him reporting requirements that restricted his
actions in selling recycling tax promotions. Mr. Greer took no
remedial actions after learning of the questionable nature of Mr.
Roberts’s tax shelter strategy; rather he purportedly relied upon
vague assurances from HG personnel.
The record establishes that Mr. Greer aggressively sought to
reduce the 1982 tax liability through Madison and consulted with
his tax return preparer about the transaction to verify the tax
benefits, not to obtain an independent opinion on the merits of
the tax scheme. Given that the expected tax refunds were 175
percent of the dollars invested, Mr. Greer’s rush to invest in
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