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T.C. 849, 888 (1987), affd. 904 F.2d. 1011 (5th Cir. 1990), affd.
on other issues 501 U.S. 868 (1991). There is nothing in this
record to indicate that whoever gave the advice was competent.
Indeed, if in fact such advice was given, the competency of the
adviser would be severely impeached by the very nature of
the advice. Respondent's determination of negligence is
sustained.4
Decision will be entered
under Rule 155.
4 Petitioners complain on brief that they had no
opportunity to "question" respondent regarding the deductions
petitioners claimed on their returns. The deductions, however,
were based on expenditures made by petitioners. We cannot
understand how respondent would have relevant information
concerning the nature of these expenditures.
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