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that the professional adviser on whom he or she relied had the
expertise and knowledge of the relevant facts to provide informed
advice on the subject matter. Freytag v. Commissioner, supra at
888.
Petitioners made no effort to ascertain the professional
background and qualifications of their return preparer. They
knew that their claimed deductions were not based on the amounts
they actually expended. That circumstance should have prompted
petitioners to determine whether such representations by their
return preparer were correct. They did not consult other tax
professionals to verify the accuracy of the returns prepared by
Mr. Beltran or the representations he made to them regarding
their deductions. The Court is satisfied from the record that
Mr. Beltran knew, or had reason to know, all the relevant facts
upon which, had he been a qualified professional, he could have
accurately advised petitioners on the amount of their allowable
deductions. Mr. Beltran listed unrealistic amounts as deductions
on petitioners' returns. Petitioners knew they were required
under the law to substantiate deductions claimed on their
returns. The circumstances should have prompted them to look
beyond and ascertain the accuracy of their preparer's
representations. Petitioners, therefore, made no effort to
assess their tax liabilities correctly. On this record, the
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