- 37 - 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 anPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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