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refund of $22,536. Petitioner was not an uneducated person, yet
she took these actions without consulting an independent adviser
concerning the viability of the partnership as an investment
vehicle, or concerning the validity of the tax claims being made
with respect thereto. Instead, on both fronts petitioner relied
completely on Mr. Hoyt--the promoter of the partnership and the
same person who was retaining the bulk of petitioner’s tax
refunds, refunds obtained by Mr. Hoyt through the preparation of
petitioner’s tax returns. Petitioner never inquired into how the
large deduction and credits were calculated, and she never
questioned their legitimacy. We find that petitioner’s actions--
with respect to the investment and with respect to the items on
her tax return and tentative refund claim--reflect a lack of due
care and a failure to do what a reasonable or ordinarily prudent
person would do under the circumstances. We therefore hold that
petitioner was negligent within the meaning of section 6653 with
respect to the entire amount of the deficiency in each year in
issue.
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