- 43 -
United States v. Boyle, supra at 251 ("Most taxpayers are not
competent to discern error in the substantive advice of an
accountant or attorney"). Accordingly, we do not sustain
respondent's imposition of the accuracy-related penalties on the
portions of the deficiencies relating to the change in accounting
method.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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