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v. Commissioner, T.C. Memo. 1995-444. Thus, petitioner's
reliance on representations made by Bambara and Taggert was not
reasonable.
Petitioner also claims that he relied on the advice of his
accountant. For reliance on professional advice to excuse a
taxpayer from negligence, the taxpayer must show that the
professional had the requisite expertise, as well as knowledge of
the pertinent facts, to provide informed advice on the particular
subject matter. See David v. Commissioner, 43 F.3d 788, 789-790
(2d Cir. 1995), affg. per curiam T.C. Memo. 1993-621; Goldman v.
Commissioner, supra; Freytag v. Commissioner, supra. A taxpayer
may not reasonably rely on the advice of an accountant who knows
nothing about the nontax business aspects of the contemplated
venture. See Freytag v. Commissioner, supra; Beck v.
Commissioner, 85 T.C. 557 (1985).
In the present cases, there is no indication that
petitioner's accountant had any knowledge of the nontax business
aspects of the Plastics Recycling leasing programs. Thus,
although petitioner's accountant prepared the returns for the
years in issue, there is no indication that petitioner ever
discussed the substantive merits of the tax treatment of items in
connection with his investments in Plymouth and Taylor. We are
not satisfied that petitioner's accountant possessed the complete
and necessary information to advise petitioner on the
deductibility of the losses or the allowability of the credits
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