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Section 6664(c)(1) provides that the penalty should not be
imposed on any portion of an underpayment if the taxpayer shows
reasonable cause for such portion of the underpayment and that
the taxpayer acted in good faith with respect to such portion.
Reliance on the advice of a professional such as an accountant
may constitute a showing of reasonable cause if, under all the
circumstances, such reliance was reasonable and the taxpayer
acted in good faith. Sec. 1.6661-6(b), Income Tax Regs.
Petitioner has failed to show that he was not negligent.
There is no evidence that petitioner made a reasonable attempt to
comply with the statutes or regulations in filing his Federal
income tax returns for any of the years at issue. Had petitioner
consulted either the relevant statutes or a competent tax adviser
he would have discovered that many of the deductions he claimed
were not proper. It is clear from the facts in this case, and
from petitioner's brief, that petitioner claimed these deductions
and expenses without regard to the applicable law. Therefore, we
sustain the accuracy-related penalty for each year as determined
by respondent.
Decisions will be
entered under Rule 155.
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