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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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