- 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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