Patrick F. and Arlene Gwon Sheehy - Page 6

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          380 F.2d 499, 506-507 (5th Cir. 1967), affg. in part and remanding                 
          in part 43 T.C. 168 (1964); Neely v. Commissioner, 85 T.C. 934, 947                
          (1985).                                                                            
                Petitioner specialized in hematology.  He believed that                      
          studying the bloodline and genetic profile of thoroughbred horses                  
          could identify future champion racehorses, and he acquired                         
          interests in racehorses, in part, to prove his theory.  He credibly                
          testifed as to his belief that the development of the bloodline of                 
          a thoroughbred horse was a "scientific endeavor".                                  
                Petitioners' accountant, Mr. Judge, advised them that they                   
          could deduct the purchase price of petitioner's interests in the                   
          racehorses as a research and experimental expense for 1991.                        
          Reasonable reliance on a professional in such a matter can shield                  
          a taxpayer from a finding of negligence.  Horn v. Commissioner, 90                 
          T.C. 908, 942 (1988); Daoust v. Commissioner, T.C. Memo. 1994-203.                 
          We believe that petitioners' reliance on Mr. Judge was in good                     
          faith.                                                                             
                Further, petitioners had claimed such a deduction for earlier                
          years, and when these returns were audited, such deductions were                   
          not disallowed.                                                                    
                Although the situation involved herein is a close case, we                   
          believe petitioners were not negligent.  Accordingly, we hold that                 









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