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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
examined the returns he prepared and admitted at trial that they
caused Mr. Beltran to revise the returns to reduce the claimed
expenses because they realized that the amounts claimed were
excessive. Yet, petitioners knew that, with the revisions
ordered by them, the expenses claimed were still excessive and
made no effort to have their returns corrected to reflect the
actual amount of their claimed deductions. The Court notes that
the unreimbursed employee business expenses claimed on the
returns, all related to Mr. Lavigne's employment, amounted to
32.6 percent and 37.4 percent, respectively, of the wages Mr.
Lavigne earned during 1998 and 1999. Mr. Lavigne admitted in his
testimony at trial that he would not accept employment that
required the employee to bear expenses of that proportion without
any reimbursement from the employer or some other source other
than himself. Petitioners did not look beyond the
representations of Mr. Beltran, knowing that the deductions at
issue were grossly inflated. Petitioners knew that they could
claim only deductions that could be substantiated. Petitioners
made no reasonable effort to ascertain their correct tax
liabilities for the years at issue. Stubblefield v.
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