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alia, that the taxpayer provided necessary and accurate
information to the adviser. See, e.g., Rule 142(a); Ellwest
Stereo Theatres of Memphis, Inc. v. Commissioner, T.C. Memo.
1995-610.5
Although the record is silent concerning Mr. Poltonowicz’s
qualifications, we are willing to assume that he was a competent
professional. Petitioners did not establish, however, that they
supplied Mr. Poltonowicz with the necessary documentation to
substantiate the costs of goods sold and the disallowed
deductions. See Johnson v. Commissioner, 74 T.C. 89, 97 (1980),
affd. 673 F.2d 262 (9th Cir. 1982). Indeed, there was no such
documentation. In sum, we find petitioners did not reasonably
rely on the advice of their accountant.
Relief From Joint and Several Liability
We initially note that Mrs. Haggart requests relief only
from the self-employment tax liabilities imposed as a result of
Mr. Haggart’s business. When, as here, a joint return is filed,
the liability for the self-employment tax of one spouse is a
5 Petitioners have not argued that either sec. 7491(a) or (c)
applies to this case to shift the burden of proof and/or
production. Sec. 7491 applies to court proceedings arising from
examinations commencing after July 22, 1998. Internal Revenue
Service Restructuring & Reform Act of 1998 (RRA), Pub. L. 105-
206, sec. 3001, 112 Stat. 726. It would appear that the
examination for 1997 commenced after that date. With regard to
the burden of proof under sec. 7491(a), petitioners have not
satisfied the requirements of that section. Under sec. 7491(c)
respondent has the burden of production with respect to the sec.
6662(a) penalties and respondent has satisfied that burden.
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