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Petitioners contend their underpayments are not due to
negligence because they reasonably relied on the advice of Mr.
Matsuda, whom they portray as a trusted professional and friend
with a good reputation throughout the community. It is well
settled that, although taxpayers may avoid liability for the
additions to tax under section 6653(a) if they reasonably relied
in good faith on a competent professional, United States v.
Boyle, 469 U.S. 241, 250-251 (1985), “Reliance on professional
advice, standing alone, is not an absolute defense to negligence,
but rather a factor to be considered”, Freytag v. Commissioner,
89 T.C. 849, 888 (1987), affd. 904 F.2d 1011 (5th Cir. 1990),
affd. 501 U.S. 868 (1991). In order to successfully claim they
reasonably relied on professional advice, petitioners must
demonstrate that the professional on whom they relied had
sufficient expertise and knowledge of the pertinent facts to
provide informed advice on the subject matter. Id.; Becker v.
Commissioner, T.C. Memo. 1996-538; Sacks v. Commissioner, T.C.
Memo. 1994-217, affd. 82 F.3d 918 (9th Cir. 1996); Kozlowski v.
Commissioner, T.C. Memo. 1993-430, affd. without published
opinion 70 F.3d 1279 (9th Cir. 1995).
Petitioners have not pointed to any advice the Myerses
received from Mr. Matsuda relevant to their reporting positions
in the taxable years before us. In 1981, Mr. Matsuda examined
the Myerses’ financial situation and determined they needed to
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