there was anything wrong with Hoyt or anything like that.” Mortensen, T.C.M. (RIA) 2004-279, 1758. The Tax Court found that “the record is completely devoid of any detail concerning what information he provided to the IRS or what information he received in return.” Id. at 1759. Finally, Mortensen claims that another coworker traveled to a Hoyt ranch to confirm that there were actually cows and an operating business. With regard to this factor, the Tax Court found that “there has been no suggestion that this coworker had any background in cattle ranching or was otherwise qualified to investigate the Hoyt organization.” The Tax Court’s decision to reject these two purported good faith reliance claims is likewise consistent with this Court’s ease law. See, e.g., Leuhsler, 963 F.2d at 910 (<HOLDING>). Again, there is no evidence that the Tax
holding that knowing reliance upon the advice of a nonattorney cannot support a claim for ineffective assistance of counsel in a removal proceeding holding that even unsophisticated investors cannot escape a negligence penalty by claiming reliance on the advice of those who are not professional investment counselors holding that a receiver is not liable for loss resulting from his good faith reliance on the advice of counsel holding that a professional owes no duty to third persons unless the professional had actual knowledge that those persons would rely on his rendering of professional services holding that plaintiffs who received fraudulent tax advice and acted in reliance on the advice though only alleging a future risk of being assessed penalties for acting on the advice had alleged an injuiyinfact