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to negligence; it is only one factor to be considered. In order
for reliance on a professional adviser to relieve a taxpayer from
the negligence penalty, the taxpayer must establish 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 did
not examine the returns prepared by Mr. Beltran, except perhaps
to ascertain the amount of the refunds they would receive. The
record does not show that petitioners looked beyond that. The
Court is satisfied that petitioners knew that they could only
claim deductions on their returns that could be substantiated,
and, even if they did not know that, at the very least, the
representations that the deductible amount of such deductions was
based on a formula should have prompted them to verify the
accuracy of such a representation with a qualified preparer.
Moreover, the amounts claimed for unreimbursed employee expenses
were clearly disproportionate to petitioners' wages, which also
merited further inquiry. These facts demonstrate to the Court
that petitioners made no reasonable effort to ascertain their
correct tax liability for the years at issue. Stubblefield v.
Commissioner, supra. Additionally, when petitioners were
contacted by respondent with respect to their returns,
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