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          the promissory notes.  This trust continued even when the Hoyt              
          organization switched petitioner’s investment from partnership to           
          partnership, at times without notifying petitioner or verifying             
          the status of the promissory notes that had been signed on                  
          petitioner’s behalf.  We conclude that petitioner was negligent             
          in signing the power of attorney forms and in entering into the             
          investment.                                                                 
               In the years 1986 through 1991, petitioner used the Hoyt               
          investment to report a total Federal income tax liability of                
          $4,349 on income totaling $290,149.  In addition, petitioner                
          filed the Form 1045 which purportedly completely eliminated his             
          Federal income tax liabilities for 1983 through 1985, resulting             
          in a requested refund of $18,548.  Petitioner claimed these tax             
          benefits based solely on the advice that he received from the               
          promoters of the investment and from other Hoyt investors--                 
          petitioner never questioned the amounts on the tax returns, and             
          he never had the returns reviewed by a tax professional.                    
          Furthermore, the promotional materials that petitioner received             
          had clearly indicated that there were substantial tax risks in              
          making an investment.  Nevertheless, petitioner did not inquire             
          into the tax claims being made on his tax returns by the Hoyt               
          organization with anyone outside the organization.  This failure            
          to inquire is especially notable with respect to petitioner’s               
          1986 return and amended return.  In preparing petitioner’s                  
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