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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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