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acted on their fascination with the idea of
participating in a jojoba farming venture and their
satisfaction with tax benefits of expensing their
investments, which were clear to them from the
promoter’s presentation. They passed the offering
circular by their accountants for a "glance" * * *.
Similarly, petitioner in this case acted on an enthusiasm for the
potential uses of jojoba and acted with knowledge of the tax
benefits of making the investment. This record fails to reflect
with any certainty that Mr. Salgo actually rendered any advice to
petitioner in connection with Utah I. However, the record
suggests that what little advice Mr. Salgo may have given to
petitioner was highly generalized and based primarily on a mere
cursory review of the offering rather than on independent
knowledge, research, or analysis. Petitioner failed to show that
Mr. Salgo had the expertise and knowledge of the pertinent facts
to provide informed advice on the investment in Utah I. See
Freytag v. Commissioner, 89 T.C. at 888. Accordingly, petitioner
failed to establish that his reliance on the advice of Mr. Salgo
was reasonable or in good faith. See Glassley v. Commissioner,
supra.
The Court next examines petitioner's reliance on the advice
of Dr. Stephan. Dr. Stephan had no background or expertise in
the areas of agriculture or jojoba plants. More importantly,
because Dr. Stephan earned a commission on each sale of Utah I
interests, and thus had a personal profit motive in selling this
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