- 40 -                                         
          the matter again.  However, this contradicts the events that                
          transpired in 1991.  Prior to the lapse of the first extension              
          (before March 28, 1991), Yang as the executrix filed an                     
          application for a second extension of time to file the return to            
          March 28, 1992, but respondent denied the extension of time to              
          file on April 4, 1991.  As a result, the executrix knew that the            
          second request was denied, resulting in the return being due by             
          March 28, 1991.  This is distinct from the facts presented in               
          Estate of La Meres, where the respondent did not notify                     
          petitioner about the denial of the second extension until the               
          audit.  Id. at 321.  We think a prudent taxpayer upon                       
          notification that the second extension was denied would have                
          inquired further and would not have relied upon Wang's statement            
          that a return would not be due.                                             
               Further, while in Yang's affidavit she stated that she                 
          relied on Wang's advice "because of his education, apparent                 
          competency, and our longstanding and mutually productive                    
          relationship," her testimony at trial was less persuasive.                  
          During trial, Yang testified that Wang had performed tax services           
          for the Youngs, but she was unaware of Wang's educational                   
          background, such as where he attended school and whether he had a           
          master's degree in taxation.  While Yang was aware that Wang was            
          a certified public accountant, her testimony was unclear whether            
          she based her reliance on that fact.  See Sanders v.                        
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