- 36 -
questioning the reasonableness of petitioners' reliance
on the advice of a tax professional. Cf. Streber v.
Commissioner, 138 F.3d 216 (5th Cir. 1998), revg. T.C.
Memo. 1995-601; Reser v. Commissioner, 112 F.3d 1258 (5th
Cir. 1997), affg. in part and revg. in part and remanding
T.C. Memo. 1995-572; Chamberlain v. Commissioner, 66 F.3d
729 (5th Cir. 1995), affg. in part revg. in part T.C. Memo.
1994-228; Heasley v. Commissioner, 902 F.2d 380 (5th Cir.
1990), revg. T.C. Memo. 1988-408. Rather, there is no
credible evidence in this case that petitioners' accountant
provided them with any advice regarding the proper tax
treatment of the loans petitioner received from the plan.
Under these circumstances, we are unable to find that
petitioners acted in good faith and reasonable reliance on
the advice of a tax professional such that they should be
relieved of the accuracy-related penalty for negligence.
Cf. Pappas v. Commissioner, 78 T.C. 1078, 1092 (1982);
Sweatman v. Commissioner, T.C. Memo. 1997-468; Drummond
v. Commissioner, T.C. Memo. 1997-71; Balkissoon v.
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