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In conclusion, we find that petitioner did not reasonably rely on
any advice that he received from the professional through his
father because any such advice was not provided by someone who
had all the necessary information to make an informed decision,
and because the advice was conclusory and did not address any of
the specific risks involved in an investment, including the tax
risks. See Barlow v. Commissioner, supra; Hunt v. Commissioner,
T.C. Memo. 2001-15.
We similarly find that any reliance upon petitioner’s
coworkers to investigate the partnership was not reasonable.
With respect to the coworker who purportedly contacted the IRS,
the record is completely devoid of any detail concerning what
information he provided to the IRS or what information he
received in return. With respect to the coworker who purportedly
traveled to visit a Hoyt ranch, there has been no suggestion that
this coworker had any background in cattle ranching or was
otherwise qualified to investigate the Hoyt organization. See
Freytag v. Commissioner, supra at 888.
We note that, even if petitioner did rely upon the
individuals discussed above, any such reliance would have been 5
years before he signed the return that resulted in the penalty at
issue in this case. Petitioner’s continued reliance on any
information gained from these individuals over such a long period
of time--in light of the large losses being claimed by the
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