- 23 - petitioners were ignoring apparently correct advice previously provided by Subrin. Respondent contends that petitioners may not rely on Bailey because Subrin was their accountant during the years in issue. Respondent contends that petitioners looked for an accountant who would give the advice that resulted in the lowest tax liability. Petitioners changed from Subrin to Bailey in 1993. We think petitioners reasonably believed that Bailey was qualified to provide tax advice. We conclude that they are not liable for the addition to tax for negligence. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011