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advice from a tax professional concerning the Hoyt investment.
Petitioner’s testimony concerning his reliance on his father’s
tax professional--to whom petitioner did not pay any fee for
advice--was vague and lacked any degree of detail. In
particular, it remains unclear exactly what information was
contained in the packet that petitioner asserts he sent to his
father. Petitioner also did not provide the name of the
professional, and while he initially testified that the
professional was a tax lawyer, he later referred to him a his
father’s “tax accountant”. Petitioner provided no
contemporaneous written statement from the professional, and he
testified that because of his father’s death he was unable to
discover the professional’s name prior to trial. Petitioner’s
description of the advice from the professional was also vague,
consisting merely of a broad and conclusory statement that
nothing about the investment was illegal. Petitioner admits that
he did not personally speak with the professional, that he did
not provide him with any details concerning his particular
investment with the Hoyt organization, and that he was unsure how
much of the informational packet the professional reviewed.
Furthermore, although the professional purportedly told
petitioner’s father that there were risks involved with the
investment, petitioner did not question the professional
concerning the nature of the risks or otherwise investigate them.
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