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          the year in issue.  However, this does not alter our conclusion             
          that petitioner was negligent with respect to entering the Hoyt             
          investment, and that he was negligent with respect to the                   
          positions that he took on his 1991 tax return.  Despite Mr.                 
          Hoyt’s actions, the positions taken on the 1991 return signed by            
          petitioner were ultimately the positions of petitioner, not of              
          Mr. Hoyt.                                                                   
          V.  Conclusion                                                              
               On the basis of the record before the Court, we conclude               
          that petitioner’s actions in relation to the Hoyt investment                
          constituted a lack of due care and a failure to do what a                   
          reasonable or ordinarily prudent person would do under the                  
          circumstances.  First, petitioner entered into an investment--in            
          which he gave Mr. Hoyt the authority to incur personal debts on             
          his behalf and control his interest in his partnerships--without            
          adequately investigating the legitimacy of the partnerships.                
          Second, and foremost, petitioner trusted individuals who told him           
          that he effectively could escape paying Federal income taxes for            
          a number of years--petitioner reported a combined tax liability             
          of $4,349 on $290,149 of income over 6 years starting with 1986,            
          and reported zero tax liability on $116,170 of AGI for the prior            
          3 years--based solely upon the tax advice of the individuals                
          receiving some of the benefits of the tax savings.  Our                     
          conclusion is reinforced by the fact that petitioner received               
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