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Petitioners relied on advice from Philip Silbering
(Silbering), a certified public accountant, in connection with
the preparation of their 1990 Federal income tax return.
Petitioner had telephone conversations with Silbering and
explained the circumstances of the sale of Washington Chocolate.
Silbering advised petitioner that it would be appropriate to take
a bad debt deduction for the unpaid commissions.
Silbering also advised petitioner to prepare an explanation
of the bad debt deduction and include it with his return.
Petitioner prepared this explanation and attached it to
petitioners' 1990 Federal income tax return.
When an accountant provides advice to a taxpayer on a matter
of tax law, it may be reasonable for the taxpayer to rely on that
advice. United States v. Boyle, 469 U.S. 241, 251 (1985); Betson
v. Commissioner, 802 F.2d 365, 372 (9th Cir. 1986), affg. in part
and revg. in part T.C. Memo. 1984-264. Petitioners' reliance on
Silbering's advice regarding the bad debt was reasonable.
Moreover, the circumstances were disclosed. In addition, we find
the other issues resulting in petitioners' deficiency to be good
faith misinterpretations of the Internal Revenue Code.
Accordingly, petitioners are not liable for the accuracy-
related penalty pursuant to section 6662(a).
For the foregoing reasons,
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