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          1.  Petitioners’ Purported Reliance on an Adviser                           
               In each of these cases, petitioners claim that they                    
          reasonably relied upon Schluter’s advice.  A taxpayer may avoid             
          liability for the additions to tax under section 6653(a)(1) and             
          (2) if he or she reasonably relied on competent professional                
          advice.  See United States v. Boyle, 469 U.S. 241, 250-251                  
          (1985); Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd.             
          904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991); see               
          also American Properties, Inc. v. Commissioner, 28 T.C. 1100,               
          1116-1117 (1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958).            
          Reliance on professional advice, standing alone, is not an                  
          absolute defense to negligence, but rather a factor to be                   
          considered.  See Freytag v. Commissioner, supra.  For reliance on           
          professional advice to excuse a taxpayer from the negligence                
          additions to tax, the taxpayer must show that the professional              
          had the expertise and knowledge of the pertinent facts to provide           
          informed advice on the subject matter.  See Chakales v.                     
          Commissioner, 79 F.3d 726 (8th Cir. 1996), affg. T.C. Memo. 1994-           
          408; David v. Commissioner, 43 F.3d 788, 789-790 (2d Cir. 1995),            
          affg. T.C. Memo. 1993-621; Freytag v. Commissioner, supra; Sann             
          v. Commissioner, supra.                                                     
               Moreover, reliance on representations by insiders,                     
          promoters, or offering materials has been held an inadequate                
          defense to negligence.  See Pasternak v. Commissioner, 990 F.2d             
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