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independent parties unburdened with an inherent conflict of
interest, not from the promoters of the investment. Goldman v.
Commissioner, 39 F.3d 402, 408 (2d Cir. 1994), affg. T.C. Memo.
1993-480; LaVerne v. Commissioner, 94 T.C. at 652); Rybak v.
Commissioner, 91 T.C. 524, 565 (1988); Edwards v. Commissioner,
T.C. Memo. 2002-169.
It is clear in this case that petitioners’ reliance on the
Hoyt organization to prepare their tax returns was not
objectively reasonable. We note that petitioners did not receive
any specific advice concerning the deduction of the partnership
loss--they simply accepted whatever numbers were placed on the
return by the Hoyt organization and signed the returns as they
were presented to them. Petitioners’ reliance on the Hoyt
organization to prepare the returns was not objectively
reasonable because Mr. Hoyt and his organization created and
promoted the partnership, they completed petitioners’ tax return,
and they received the bulk of the tax benefits from doing so.
For petitioners to trust Mr. Hoyt or members of his organization
to prepare their return under these circumstances was inherently
unreasonable.
In addition to members of the Hoyt organization itself,
petitioners argue that they relied on tax professionals hired by
the Hoyt organization. Petitioners, however, have only
established that they believed that the Hoyt organization had
consulted with tax professionals. Petitioners have not
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