- 32 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: May 25, 2011