John H. Miner and Holly K. Miner - Page 23




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          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.                          

























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