- 30 -
sec. 6664(c); Freytag v. Commissioner, 89 T.C. 849, 888
(1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501
U.S. 868 (1991); sec. 1.6664-4(b)(1), Income Tax Regs.
Such reliance is not an absolute defense to negligence
but merely a factor to be considered. See Freytag v.
Commissioner, supra. When a taxpayer claims reliance on
an accountant, the taxpayer must establish that correct
information was provided to the accountant and that the
item was incorrectly claimed as a result of the
accountant's error. See id.; Ma-Tran Corp. v. Commis-
sioner, 70 T.C. 158, 173 (1978); Pessin v. Commissioner,
59 T.C. 473, 489 (1972). Petitioners bear the burden of
proving that their reliance on professional advice was
reasonable. See Rule 142(a); Freytag v. Commissioner,
supra.
In this case, the record shows that petitioners'
returns for 1990 and 1991 were prepared by the accounting
firm of Glen & Graf. However, neither Mr. Glen nor any
member of Glen & Graf testified at trial. Petitioners
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