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Petitioner contends that he relied on the advice of his
accountants in reducing the income received from Besco by the
alleged expenses and that such reliance precludes a finding of
fraudulent intent. For petitioner to prevail on his reliance
argument, however, he must have provided his accountants with
full and correct information. Estate of Temple v. Commissioner,
67 T.C. 143 (1976); see Morris v. Commissioner, T.C. Memo. 1992-
635, affd. without published opinion 15 F.3d 1079 (5th Cir.
1994). In this case, petitioner's alleged reliance does not
preclude a finding of fraudulent intent.
Petitioner maintains that his accountants were fully aware
of the "nature" of the payment arrangement between Besco and
petitioner when they advised petitioner to take a deduction for
the expenses at issue. This contention does little more than
suggest that petitioner's accountants conspired to defraud the
Government. It does not, however, address whether petitioner
provided his accountants with full and correct information
regarding the alleged expenses at issue. Petitioner, not his
accountants, handled his affairs. The record lacks sufficient
evidence for us to conclude that petitioner provided his
accountants with full and correct information so as to justify
petitioner's reliance on an accountant's advice. Because
petitioner's return preparer for 1983 testified that he could not
recall how petitioner informed him of the alleged expenses at
issue, and because petitioner declined to testify, all that is
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