Gilfred B. and Patricia Swartz - Page 17




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          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                 
          deduction.  We find that it was negligent for petitioners to have           
          claimed this deduction under the circumstances of this case.  We            
          sustain respondent’s determination that petitioners are liable              
          for the section 6653(a)(1) and (2) additions to tax for                     
          negligence.                                                                 
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               

























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