but $614 was substantiated by petitioners. In the notice of
deficiency, respondent determined that petitioners overstated
their mortgage interest deductions for 1987 and 1988 by $614 and
$8,315, respectively. On brief, respondent conceded a portion of
the mortgage interest deduction for 1988, and $1,935 remains in
controversy for 1988. Petitioners failed to present any evidence
substantiating the disallowed mortgage interest of $614 for 1987
or the $1,935 remaining in dispute for 1988. Accordingly,
petitioners are not entitled to deductions for mortgage interest
for 1987 and 1988 in excess of the amounts determined by or
agreed to by respondent.
VII. Negligence
Negligence includes a lack of due care or a failure to do
what a reasonable and ordinarily prudent person would do under
the circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985). Petitioners bear the burden of proving that respondent's
determination of negligence is erroneous. Rule 142(a); Bixby v.
Commissioner, 58 T.C. 757, 791-792 (1972).
A taxpayer can avoid liability for the addition to tax for
negligence if the taxpayer can show that he reasonably relied on
the advice of a competent and experienced accountant or attorney
to prepare his return. Weis v. Commissioner, 94 T.C. 473, 487
(1990); Conlorez Corp. v. Commissioner, 51 T.C. 467, 475 (1968).
The taxpayer must show that all necessary information was
supplied to the return preparer and that the error on the return
resulted from the preparer's mistake. Pessin v. Commissioner, 59
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