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that Mr. Trimboli was an outsider who coincidentally prepared the
partnership’s return and the Schedules K-1, we find that Mr.
Trimboli’s relationship with the partnership and its principals
makes him more than a disinterested commission-based salesman, as
was the case in Anderson. In light of his relationship to Arid
Land, Mr. Trimboli cannot be considered to be an independent
adviser.
Second, the investment adviser in Anderson was a good friend
of the taxpayer. Petitioners’ purely professional relationships
with Mr. Trimboli, spanning no more than several years, are not
analogous to the close friendship between taxpayer and adviser in
Anderson. See also Dyckman v. Commissioner, T.C. Memo. 1999-79
(taxpayers reasonably relied on an adviser who was a close
personal friend); Reile v. Commissioner, T.C. Memo. 1992-488
(taxpayers reasonably relied on advice from an adviser who was an
acquaintance and fellow “temple recommend holder”). Furthermore,
petitioners’ professional dealings with Mr. Trimboli were only in
the context of an accountant-client relationship (or that of a
coworker, as was the case with Mrs. Gordon-Wylie). No petitioner
could have had prior dealings with Mr. Trimboli as a financial
planner because he had no experience in the field prior to 1983.
Cf. Wright v. Commissioner, T.C. Memo. 1994-288 (taxpayers
reasonably relied upon an individual who was recommended to them
as a financial adviser, who had a strong presence in the
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