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advice that he received is in no manner objectively reasonable.
Mr. Hoyt and his organization created and promoted the
partnership, they completed petitioner’s tax return, and they
received the bulk of the tax benefits from doing so. For
petitioner to trust Mr. Hoyt or members of his organization for
tax advice and/or to prepare his return under these circumstances
was inherently unreasonable.
In addition to members of the Hoyt organization itself,
petitioner argues that he relied on tax professionals hired by
the Hoyt organization and on other Hoyt investors. Petitioner,
however, has only established that he believed that the Hoyt
organization and the other partners had consulted with tax
professionals. Petitioner has not established in what manner he
personally relied upon any such professionals, or even the
details of what advice the professionals provided that would be
applicable to petitioner’s situation with respect to the year in
issue. Furthermore, because all of these individuals were
affiliated with the Hoyt organization, it would have been
objectively unreasonable for petitioner to rely upon them in
claiming the tax benefits advertised by that very organization.
2. Petitioner’s Early Investigation
Petitioner next argues that he had reasonable cause for the
underpayment because he made a reasonable investigation into the
partnership. Petitioner asserts that this investigation yielded
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