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Gordon-Wylie worked as a receptionist and clerk at Bugni, LaBanca
& Paduano during 1983. Both of the Gordon-Wylies had limited
investing experience.
Mrs. Gordon-Wylie met Mr. Trimboli several years prior to
1983 while working at Bugni, LaBanca & Paduano. Mr. Gordon-Wylie
was introduced to Mr. Trimboli in 1983, when Mr. Trimboli began
preparing the Gordon-Wylies’ tax returns as well as assisting
them with financial planning. In December 1983, the Gordon-
Wylies purchased six units in Arid Land through Mr. Trimboli for
a total of $6,600 in cash and a promissory note of $9,900.
The Gordon-Wylies filed a joint Federal income tax return
for the taxable year 1983. On this return, they reported the
following amounts of income and loss:4
Wages $63,673
Interest income 276
Dividends 978
Capital loss (1,153)
Rental loss (2,943)
Subtotal 60,831
Arid Land loss (14,888)
Total income 45,943
Mr. Trimboli prepared the Gordon-Wylies’ return for taxable year
1983.
Following the entry of the decision concerning the
partnership, discussed above, respondent adjusted the Gordon-
Wylies’ return by disallowing their claimed share of the
4See supra note 3.
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