Robert G. Leslie and Marilyn B. Leslie - Page 15

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          during the years he prepared petitioners' tax returns at Edward             
          White & Co. and for all the taxable years at issue.                         
               Petitioner relied on Short to find investments that satis-             
          fied his investment criteria because petitioner did not have time           
          to personally investigate all of the potential investments in               
          which he was interested.  As part of Short's investigation of               
          potential investments for petitioner, Short read books, articles,           
          and periodicals relating to commodity trading which led Short to            
          believe that this type of investment met petitioner's investment            
               Since neither Short nor petitioner had prior experience with           
          commodity investments, Short searched for brokerage firms that              
          had commodity departments.  Short searched for a commodity broker           
          by contacting brokerage houses and persons he had worked for in             
          the past, including Edward White & Co.  These sources led Short             
          to Hunter and, in particular, to Russ Klein (Klein), who was                
          employed by and in charge of Hunter.                                        
               Short met with Klein on three occasions before investing               
          with Hunter.  Petitioner only attended the last meeting.  The               
          initial meeting with Klein focused on commodity trading methods             
          and a projected potential return of 25-47 percent.  Short                   
          believed that the Hunter trading methods met all of petitioner's            
          investment criteria.  Additionally, Short believed that Klein               
          would be able to educate him in commodity trading strategies in             
          order to enable him to assume increasing degrees of control over            

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