- 24 - information to his accountant and that the incorrect returns were the result of the accountant’s mistake. Enoch v. Commissioner, 57 T.C. 781, 803 (1972). Petitioner testified that he sought the advice of Bobrow with regard to deducting losses resulting from Mary Catherine’s having been required by its mortgage lenders to write down the Ridge and Minnechaug to fair market value for financial statement purposes. Bobrow then prepared petitioners’ returns including detailed statements disclosing the nature of the writedowns and resulting losses. Attached to the disclosure statements are the appraisals and other information about the Ridge and Minnechaug. Examination of Mary Catherine’s and petitioners’ income tax returns reveals that petitioner must have provided Bobrow with all information necessary for his accountants to render tax advice and prepare the returns. We find that petitioners relied on the advice of Bobrow, and we hold that petitioners were not negligent in doing so. Petitioners made no effort to hide their position from respondent. Petitioners attached copies of Mary Catherine’s income tax returns, including the disclosure statements, to their personal returns. Petitioners also attached copies of the disclosure statements to each Application for Tentative Refund that they filed. The completeness and clarity of petitioners’ disclosure statements, and the fact that petitioners attached aPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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