26 U.S.C.A. 6700: Promoting Abusive Tax Shelters
"Defendant could not be held liable under abusive tax shelter statute, where there was no evidence that defendant directly and personally made or furnished the gross valuation overstatements to any investor, notwithstanding claim that statute should be broadly construed to hold an individual liable if another with whom he has associated has made or furnished statements described in statute. U.S. v. Turner, E.D.Wis.1985, 601 F.Supp. 757, affirmed 787 F.2d 595. Internal Revenue
5203"
IRS Abusive Promotions Training Manual,
Training 3118b-002