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v. Commissioner, 94 T.C. 473, 487 (1990); Ewing v. Commissioner,
91 T.C. 396, 423-424 (1988), affd. without published opinion 940
F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, 89 T.C. 849,
888 (1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S.
868 (1991); Jackson v. Commissioner, 86 T.C. 492, 539 (1986),
affd. 864 F.2d 1521 (10th Cir. 1989); Brown v. Commissioner, 47
T.C. 399, 410 (1967), affd. 398 F.2d. 832 (6th Cir. 1968).
However, reliance on professional advice, standing alone, is not
an absolute defense to negligence, but only one factor to be
considered. Freytag v. Commissioner, supra; Reimann v.
Commissioner, T.C. Memo. 1996-84; Kaplan v. Commissioner, T.C.
Memo. 1994-81. A taxpayer's reliance must be reasonable, in good
faith, and based on full disclosure. Ewing v. Commissioner,
supra; Pritchett v. Commissioner, 63 T.C. 149, 174-175 (1974).
Further, reliance on a tax professional will not absolve
taxpayers where they are aware that the "facts" upon which they
predicate their deductions are not the facts of the transaction
in issue. McCrary v. Commissioner, 92 T.C. 827, 847 (1989).
Dr. Glassley testified that he relied on his accountant in
claiming the disputed expenditures while Dr. Houser testified
that he relied on his accountant and his brother, an attorney.
To show good faith reliance, petitioners Glassley and Houser must
establish that these individuals were competent to render the
advice, that petitioners supplied them with all necessary
information, and that the incorrect return was a result of the
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