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               Petitioner contends that he was not negligent because (1) he           
          reasonably relied upon the advice of independent advisers and (2)           
          he reasonably expected to make a profit from his purchase of the            
          Sentinel EPE and EPS recyclers.  Respondent, on the other hand,             
          contends that petitioner's reliance on Ulanoff, Burstein, WMDI,             
          and Boylan & Evans was not reasonable, and that it was not                  
          reasonable for petitioner to expect to profit from his purchase             
          of the Sentinel recyclers.                                                  
               Under some circumstances, a taxpayer may avoid liability for           
          negligence if reasonable reliance on a competent professional               
          adviser is shown.  United States v. Boyle, 469 U.S. 241, 250-251            
          (1985); Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd.             
          904 F.2d 1011 (5th Cir. 1990), affd 501 U.S. 868 (1991).                    
          Reliance on professional advice, standing alone, is not an                  
          absolute defense to negligence, but rather a factor to be                   
          considered.  Freytag v. Commissioner, supra.  For reliance on               
          professional advice to excuse a taxpayer from negligence, the               
          taxpayer must show that the professional had the requisite                  
          expertise, as well as knowledge of the pertinent facts, to                  
          provide informed advice on the subject matter.  David v.                    
          Commissioner, 43 F.3d 788, 789-790 (2d Cir. 1995), affg. T.C.               
          Memo. 1993-621; Goldman v. Commissioner, 39 F.3d 402 (2d Cir.               
          1994), affg. T.C. Memo. 1993-480; Freytag v. Commissioner, supra.           
               Reliance on representations by insiders or promoters has               
          been held an inadequate defense to negligence.  Goldman v.                  
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