- 11 - v. Commissioner, 118 F.3d 184, 188 (4th Cir. 1997), affg. T.C. Memo. 1996-167; Freytag v. Commissioner, supra at 888. The Court's review of the evidence in this case leads to the conclusion that petitioners did not place reasonable reliance, in good faith, on a competent professional adviser in making their investment in the Arid Land partnership. According to petitioner's testimony, after a perfunctory discussion with what he thought was an insurance agent, the agent recommended that he invest in a jojoba research and experimentation limited partnership. Petitioner implied that the switch in investment focus from life insurance to jojoba research was not remarkable to him, even though this was his first involvement with Desmond. Petitioners did not receive, and apparently did not request, a private placement letter, prospectus, or any other document describing their investment. Petitioner testified that Desmond provided a copy of a bill passed by Congress encouraging jojoba cultivation and some newspaper articles on the subject that convinced him of the validity of the investment. Petitioner presented as exhibits items similar to those described in his testimony, but they all postdate his investment in Arid Land. Petitioner also seemed relatively unconcerned by being solicited to invest in an entity called "New Jersey Agri 83-1" and being placed in one called Arid Land Research Partners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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