- 31 - 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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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