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          made any separate payment for professional services by Dooskin              
          and Sacco, and consequently they could not expect the accountants           
          to do more than read the memorandum for form and apparent                   
          professionalism, potential benefits, and obvious dangers.                   
               C.  Petitioners’ Relationship With Becker and Miller                   
               Regardless of the foregoing, petitioners contend that                  
          petitioner’s alleged “deep and longstanding professional                    
          relationship” with his advisers justified his reliance on them.             
          We disagree.  See Barlow v. Commissioner, T.C. Memo. 2000-339;              
          cf. Dyckman v. Commissioner, T.C. Memo. 1999-79; Zidanich v.                
          Commissioner, T.C. Memo. 1995-382.  Petitioner was sufficiently             
          experienced and sophisticated to know that SAB Foam was a tax               
          shelter, and that the value of the transaction depended on the              
          value of the underlying assets, and he failed to consult either             
          an independent appraiser or anyone with expertise in plastics               
          recycling.                                                                  
               In addition, the evidence does not support petitioners’                
          claims that he had a unique and special relationship with his               
          advisers Becker and Miller.  Cf. Dyckman v. Commissioner, supra             
          (absolving taxpayers from the negligence penalty, in part,                  
          because of the long-term special relationship of trust and                  
          friendship between the taxpayers and their adviser).                        
               First, petitioner claims to have a particularly close                  
          relationship with Becker.  Petitioner testified that he “had an             
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