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Mr. Ellison talked with petitioner about the Hoyt partnerships
and showed her Hoyt partnerships promotional materials.
Petitioner attended a Hoyt investor meeting.
Petitioner was not interested in investing in the Hoyt
partnerships. Petitioner was skeptical regarding how an
investment in the Hoyt partnerships would reduce her tax
liability and would generate large tax refunds. Petitioner did
not think it would work.
Mr. Ellison sought advice from an attorney about the Hoyt
partnerships. The attorney told Mr. Ellison that it was a risky
investment, but that if the Hoyt organization did what it said it
would do that it was legal.
Mr. Ellison told petitioner that he investigated the Hoyt
partnerships. Petitioner did not know, or ask Mr. Ellison, who
he had talked to or how he had obtained his information (i.e.,
whether it was from an attorney, a tax professional, someone
outside or inside the Hoyt organization, a co-worker of Mr.
Ellison, etc.). Petitioner never suggested seeking the advice of
someone outside the Hoyt organization regarding the Hoyt
partnerships.
Mr. Ellison persuaded petitioner to invest in the Hoyt
partnerships. There was no hostility or threats. Mr. Ellison
did not force petitioner to invest in the Hoyt partnerships.
Petitioner signed the Hoyt partnerships investment documents. In
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