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can Properties, Inc. v. Commissioner, 28 T.C. 1100, 1116-1117
(1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958). Reliance
on a professional adviser, standing alone, is not an absolute
defense to negligence; it is only one factor to be considered.
Freytag v. Commissioner, supra at 888. In order for reliance on
a professional adviser to excuse a taxpayer from the accuracy-
related penalty for negligence, the taxpayer must establish that
the professional adviser on whom he or she relied had the exper-
tise and knowledge of the relevant facts to provide informed
advice on the subject matter. See id.
Contrary to petitioners' contention that they have shown
that they "took great care in keeping records", we have found
that there is no evidence in the record to establish (1) when any
documents that are part of the record and that are, or purport to
be, petitioners' records were prepared and (2) whether any such
documents are complete and accurate. With respect to petition-
ers' contention that they have shown that all of the deductions
that respondent disallowed in the notice are "legal, justified,
and proven", we have found that they have not established that
they are entitled to those deductions.
With respect to any contention by petitioners that they
should not be liable under section 6662(a) because they relied on
Mr. Grenville-Jones, who prepared their 1993 return (as well as
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