Pine Creek Farms, Ltd. - Page 10
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Income Tax Regs. Reliance on the advice of an accountant may
demonstrate reasonable cause and good faith. United States v.
Boyle, 469 U.S. 241, 250-151 (1985); sec. 1.6664-4(b)(1), Income
In this case, the tax consequences regarding the futures
transactions and the ownership of the various corporations were
fairly complex. Petitioner's tax returns were prepared by its
accountant. Petitioner relied upon the accountant's advice. We
find that petitioner had reasonable cause for the underpayment of
tax and acted in good faith. Accordingly, we hold for petitioner
as to the section 6662(a) penalty.
Decision will be entered
for respondent as to the
deficiency and for petitioner
as to the penalty.
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