Theldon and Mary Parrett - Page 9

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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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