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For reliance on professional advice to excuse a taxpayer
from the negligence additions to tax, the taxpayer must show that
the professional adviser had the expertise and knowledge of the
pertinent facts to provide informed advice on the subject matter.
Leonhart v. Commissioner, supra; Freytag v. Commissioner, supra;
Stone v. Commissioner, T.C. Memo. 1996-230; Reimann v.
Commissioner, T.C. Memo. 1996-84. Reliance on a professional
adviser can be inadequate when the taxpayer and his adviser knew
nothing about the nontax business aspects of the venture. Beck
v. Commissioner, 85 T.C. 557 (1985); Flowers v. Commissioner, 80
T.C. 914 (1983). In order for reliance on professional advice to
excuse a taxpayer from the negligence additions to tax, the
reliance must be reasonable, in good faith, and based upon full
disclosure. Zfass v. Commissioner, 118 F.3d 184, 188 (4th Cir.
1997), affg. T.C. Memo. 1996-167; Freytag v. Commissioner, supra
at 888.
By the time petitioners purchased their interest in Mid
Continent in 1983, their tax returns show that they had acquired
interests in several partnerships. Petitioner had built "from
nothing" a furniture manufacturing business that was capable of
providing his family with an income of over $800,000 in 1982 and
more than $500,000 in both 1983 and 1984. Although not highly
educated in a formal sense, petitioner is articulate and
intelligent and has a history of financial success in the
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