Daniel C. Greer and Winnie L. Greer - Page 19

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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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