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even if the advice is incorrect and results in a deficiency. See
Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d
1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991).
Petitioners provided all of their records to their
accountant. Since petitioners’ Schedule C loss was allowed after
the audit for taxable year 1987, the accountant continued
treating it as a business without question to petitioners. We
find that petitioners reasonably and in good faith relied on
their accountant’s advice. Therefore, we hold that petitioners
are not liable for the accuracy-related penalty for the year at
issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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