Jeffrey C. and Kelly O. Stone - Page 11

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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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