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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, Mr.
Beltran. They failed to examine the returns prepared by Mr.
Beltran, except to ascertain the amount of the refunds they could
expect. Petitioners did not look beyond that, as they were
obviously interested more in the recommendation they had received
on Mr. Beltran that "this man can get you more money back on your
taxes than what you've been getting." The Court is satisfied
that petitioners knew they could only claim deductions that could
be substantiated, and, when their returns reflected refunds
considerably higher than what they normally would have received,
their failure to examine the returns or to have someone examine
the returns for them to ascertain the reasons for such
overpayments, constitutes negligence or disregard of rules or
regulations. Petitioners consciously failed to examine the
returns because they knew that the returns must have contained
information that was false. With the obvious reservations
petitioners had or should have had, they, nevertheless, failed to
ascertain from tax professionals whether their returns were
correctly prepared. These facts demonstrate to the Court that
petitioners made no reasonable effort to ascertain their correct
tax liabilities for the years at issue. Stubblefield v.
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