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preparer was reasonable because petitioner provided him with
Madison’s Schedule K-1 and because petitioner’s return preparer
prepared petitioner’s 1982 return using the Schedule K-1 without
questioning the investment. Petitioner’s argument does not
persuade us.
Petitioner admitted that he did not give the POM to his
return preparer, and he did not ask his return preparer to
evaluate the Madison investment before he made it. These facts
alone are enough to reject petitioner’s argument. Petitioner
also failed to present any evidence that the return preparer had
the necessary experience, training, or information to evaluate
the Madison investment, even if petitioner had asked him to
perform an evaluation. Petitioner has not carried his burden of
proving that his claimed reliance on his return preparer was
credible or reasonable.
ii. HG&C
Petitioner contends that he did not provide the POM to his
tax return preparer because he believed HG&C was his tax adviser
and because HG&C went over the POM in detail and obtained the
Boylan & Evans limited partner opinion. Petitioner’s reliance
on HG&C was not reasonable, however, because he knew that HG&C
had no background in plastics recycling technology and that Mr.
Cole, his primary contact at HG&C, not only lacked expertise in
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