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promoter’s presentation. They passed the offering
circular by their accountants for a "glance" * * *.
Similarly, petitioner here acted on his enthusiasm for the
potential uses of jojoba and acted with knowledge of the tax
benefits of making the investment. The evidence in this record
suggests that the nature of the advice given by Mr. McDevitt 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. McDevitt had the
expertise and knowledge of the pertinent facts to provide
informed advice on the investment in Blythe I. See Freytag v.
Commissioner, 89 T.C. at 888. Accordingly, petitioner failed to
establish that his reliance on the advice of Mr. McDevitt was
reasonable or in good faith. See Glassley v. Commissioner,
supra.
The Court next examines petitioner's reliance on the advice
of Mr. Moore. Petitioner admitted that he relied heavily on the
advice of Mr. Moore and the information contained in the offering
in making his investment in Blythe I. Yet, Mr. Moore also had no
background or expertise in the areas of agriculture or jojoba
plants. In fact, it appears that nearly all other potential
investments recommended to petitioner by Mr. Moore in his
financial analysis were real estate investments, and that Blythe
I was the only investment of an agricultural nature advocated by
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