- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011