Robert G. Leslie and Marilyn B. Leslie - Page 14

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          U.S. Army.  After being honorably discharged from the Army in               
          1953, petitioner entered the construction business.  Petitioner             
          eventually became the president and sole shareholder of R&H                 
          Paving, Inc., a paving contractor.                                          
               Prior to making the commodity trades with Hunter, petitioner           
          held various investments during the 1970's and early 1980's.                
          Petitioner's basic requirement in an investment was a good cash-            
          flow, in order to counter the cyclical nature of his construction           
          business.  Petitioner was not averse to risk in an investment               
          since he was accustomed to a considerable amount of risk from the           
          construction industry.                                                      
               Generally, petitioner relied on either Roy Tolson, an                  
          accountant and business adviser, or Joe Rasey, a business                   
          associate, to locate investments which satisfied his investment             
          criteria.  Before making an investment, petitioner would                    
          personally analyze the transaction.                                         
               In June 1980, petitioner hired Donald Short (Short) to be              
          his personal business adviser and controller for R&H Paving, Inc.           
          Short was a certified public accountant (C.P.A.), licensed to               
          practice in California.  Prior to being hired by petitioner,                
          Short was employed by Edward White & Co., the C.P.A. firm that              
          prepared petitioners' tax returns.  While Short worked at Edward            
          White & Co., he prepared petitioners' tax returns.  Short                   
          testified that he was well aware of petitioner's tax position               

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