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Petitioners have not established that they used reasonable
care in ascertaining their income tax liability for these years.
They have not shown that they reasonably relied on a competent
professional adviser independent of those persons who were
involved in marketing these abusive trusts. We sustain
respondent’s determinations on this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011