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Petitioner was born in Greece and came to the United States
at age 12. He attended grammar school in the United States, with
his last grade level attended being the fifth grade at age 15.
Petitioner has been a commercial real estate broker for
several years, acting primarily as a broker of strip shopping
centers.
Petitioner has limited knowledge of Federal income taxes,
and relied on professional advisers for tax advice and the
preparation of his tax returns. Martin Sugarman, a certified
public accountant, prepared petitioners' 1988 Federal income tax
return in accordance with the instructions of Ken McPhaill, a tax
manager of a national accounting firm, who died prior to the
trial of this case. Mr. McPhaill orally advised Coastal on the
overall Federal income tax treatment of the transaction at issue,
and his firm prepared Coastal's 1988 return of partnership
income.
Pecaris Partnership
In 1975, petitioner, with Christ Spillas and Peter Boyas,
formed Pecaris, an Ohio general partnership. Pecaris was formed
to acquire commercial real estate, and acquired and held various
properties.
Mr. Boyas provided the initial financing for Pecaris, but
has had no role in its day-to-day affairs. Mr. Spillas collected
and posted rents and paid payables, kept the books of the
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