-16-
with respect to reasonable cause. Higbee v. Commissioner, supra
at 446.
Where a taxpayer chooses a competent tax adviser and
supplies him or her with all relevant information, it is
consistent with ordinary business care and prudence to rely on
the adviser’s professional judgment as to the taxpayer’s tax
obligations. United States v. Boyle, 469 U.S. 241, 250-251
(1985). The taxpayer must show that the adviser was a competent
professional with significant expertise to justify reliance.
Neonatology Associates, P.A. v. Commissioner, 115 T.C. 43, 99
(2000), affd. 299 F.3d 221 (3d Cir. 2002).
Petitioners failed to assert any arguments that the
accuracy-related penalties should not apply. Petitioners rested
instead on their argument that they were eligible for the
exclusions from income under sections 119 and 912 that respondent
disallowed. Specifically, petitioners did not argue and did not
introduce any evidence that they acted with reasonable cause or
in good faith with respect to the underpayments for the relevant
years.
Mr. and Mrs. Hargrove did not use a tax return preparer and
did not seek advice from a tax professional concerning their
returns for the relevant years. While Mr. and Mrs. Breeding used
a tax return preparer to assist with their returns for the
relevant years, they did not introduce evidence regarding the
preparer. They have not shown, for example, that the preparer
was a competent professional with significant expertise to
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