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91 T.C. 524, 565 (1988).
Petitioner also contends that he reasonably relied on advice
from Mr. Jacobs. At the time of trial, Mr. Jacobs was deceased;
accordingly, we do not know first hand what knowledge he may have
had or what advice he may have given. The record does establish
that Mr. Jacobs only became involved in the farming of jojoba in
or about 1982, so his experience was limited, and there is
nothing to suggest that he was knowledgeable about research and
development of jojoba. See Freytag v. Commissioner, 89 T.C. at
888. The record also establishes that Mr. Jacobs was involved in
the sale of limited partnership interests in a number of jojoba
partnerships. Accordingly, any advice that he may have given can
be analogized to that of a promoter, which advice is inherently
suspect. E.g., Addington v. Commissioner, 205 F.3d at 59;
Pasternak v. Commissioner, 990 F.2d at 903.
In Glassley v. Commissioner, T.C. Memo. 1996-206, we found
that the taxpayers:
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” * * *.
The record in the present case suggests that whatever advice may
have been given by Mr. Jacobs was nothing more than a generalized
affirmation to invest in jojoba. Indeed, at trial, petitioner
testified that Mr. Jacobs was “very high on the investments in
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