Marvin W. and Kathryn A. McPike - Page 5

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          filing, answering telephones, and general office work.  She is              
          now retired.  Mrs. McPike has no previous investment experience             
          other than her personal residence.                                          
               Prior to 1982, petitioners either prepared their own tax               
          returns or hired someone to prepare them.  They did not have a              
          regular return preparer.  In 1982, petitioners saw an                       
          advertisement in a local newspaper for tax return preparation by            
          Daniel Lukensow (Lukensow).  According to the advertisement,                
          Lukensow's background consisted of 7 years as an internal revenue           
          agent and 8 years of private practice in the areas of tax law,              
          tax return preparation, and tax audits.  Petitioners contacted              
          Lukensow, made an appointment, and hired him to be their tax                
          return preparer.  They never investigated Lukensow's background.            
              Lukensow advised petitioners that they could save a                    
          considerable amount of money through investment in tax shelters.            
          He promoted and sold two different tax shelters, one involving a            
          computer rental program and the other involving a marine dry                
          cargo container program.  Petitioner discussed these programs               
          with Lukensow, but Mrs. McPike was not involved.  She relied on             
          petitioner to make the decisions regarding investments.                     
          Petitioner believed that the proposed investments would reduce              
          their Federal income tax liability, allow them to provide better            
          financial assistance to their blind son, and generate a pension             
          after their retirement.                                                     
               In 1983, petitioners invested in the container leasing                 




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