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with expertise in plastics recycling. If Clothier had made a
reasonable effort to determine the fair market value of the
recyclers, he would have determined that the recyclers’ price was
grossly inflated. At that point a reasonable person would have
inquired why the partnership would be willing to “invest” in
machines at far in excess of their fair market value when it
could have purchased other much less expensive machines that
performed virtually the same functions. It was not reasonable
for petitioners to claim the substantial tax credits and
partnership losses in issue on the basis of Clothier’s advice.
Petitioners compare their relationship with Clothier to the
relationships that the taxpayers had with their advisers in
Dyckman v. Commissioner, T.C. Memo. 1999-79, and Zidanich v.
Commissioner, T.C. Memo. 1995-382. Such comparisons are
misplaced. In Dyckman v. Commissioner, supra, the taxpayers were
close friends with their accountant, Mr. Kipness, as well as his
family. Mrs. Dyckman tutored Mr. Kipness’s daughter. When Mr.
Kipness and his family moved from New Jersey to California, the
Dyckmans continued to mail Mr. Kipness their tax information, and
he continued to prepare their returns for some time after the
move to California. Id. In Zidanich v. Commissioner, supra,
Mrs. Zidanich worked for the adviser’s father and subsequently
for the adviser himself for 23 years. As to the other taxpayers
in Zidanich, the Steinbergs, Mrs. Steinberg relied entirely on
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