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$12,407 (26.3 percent of their income).8 These disproportionate
and accelerated losses--along with the resulting substantial tax
savings--should have been further warning to petitioners for the
need to obtain outside, independent advice regarding the
propriety of the deduction. Despite these warnings, petitioners
did not seek such advice or conduct any other type of inquiry
into the propriety of the deductions. We find that it was
negligent for petitioners to have claimed these deductions under
the circumstances of these cases. We sustain respondent’s
determinations that petitioners are liable for the section
6653(a)(1) and (2) additions to tax for negligence.
To reflect the foregoing,
Decisions will be entered
for respondent.
8See supra note 3.
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