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her brother as her adviser and trustee of the funds that she and
her brother had inherited from their parents. Mrs. Steinberg did
not even know of the investment until the Internal Revenue
Service contacted her. In view of her brother’s highly
successful career as an investor and investment manager, her
entrustment of her funds to him was not unreasonable. Id.
Here, there is no evidence of a personal friendship between
Clothier and petitioners outside of an accountant/client
relationship. Clothier was a college acquaintance of
petitioner’s brother-–not petitioner. Petitioners terminated
their relationship with Clothier because a distance of 45 miles
was too great an obstacle. The Dyckmans continued to use their
accountant despite his permanent move with his family across the
country. In sum, petitioners’ relationship with Clothier was not
the long-term relationship of friendship and trust with an
adviser that was present in the Dyckman and Zidanich cases.
For the foregoing reasons, petitioners’ reliance on Dyckman
v. Commissioner, supra, and Zidanich v. Commissioner, supra, is
misplaced.
In conclusion, we find that petitioners failed to exercise
due care in claiming large deductions and tax credits with
respect to Whitman on their Federal income tax returns. The
disproportionately large tax benefits claimed on petitioners’
Federal income tax returns, relative to the dollar amount
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