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Id. Reliance on a qualified professional such as an
attorney or accountant may demonstrate reasonable cause
and good faith, if the evidence shows that the taxpayer
contacted a competent tax adviser and provided the adviser
with all necessary and relevant information. See Patin
v. Commissioner, 88 T.C. 1086, 1130 (1987), affd. without
published opinion 865 F.2d 1264 (5th Cir. 1989), affd. sub
nom. Gomberg v. Commissioner, 868 F.2d 865 (6th Cir. 1989),
affd. sub nom. Skeen v. Commissioner, 864 F.2d 93 (9th Cir.
1989), affd. without published opinion sub nom. Hatheway
v. Commissioner, 856 F.2d 186 (4th Cir. 1988); Freytag v.
Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011
(5th Cir. 1990), affd. 501 U.S. 868 (1991).
We acknowledge that petitioner had a longstanding
relationship with the same firm of certified public
accountants who had initially advised petitioner concerning
the creation of its accounting system. However, in this
case, there is no evidence that the errors in petitioner's
1990 income tax return resulted from advice given to it by
its certified public accountants. Mr. Hinman, who assumed
primary responsibility for petitioner's tax returns in
1987, testified that he did not review petitioner's method
of accounting for interest. Similarly, there is no
evidence that he advised petitioner to omit income by
booking receipts to account 312 or in any other fashion,
or that he advised petitioner to deduct personal expenses
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