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downtown office. In addition, petitioner gave Mr. Stoller a
sheet of paper on which she had compiled the information from her
daily calendar relating to her meals expenses.
Pursuant to section 6662(a), if any portion of an
underpayment of tax is due to negligence or disregard of rules or
regulations, the taxpayer is liable for an amount equal to 20
percent of the portion of the underpayment attributable to such
negligence or disregard of the rules and regulations.
"Negligence" includes any failure to make a reasonable attempt to
comply with the provisions of the Internal Revenue Code and
"disregard" includes any careless, reckless, or intentional
disregard. Sec. 6662(c). Petitioner has the burden of proof on
this issue. Bixby v. Commissioner, 58 T.C. 757, 791 (1972).
If a taxpayer relies in good faith upon the advice of a
competent and experienced accountant in the preparation of the
taxpayer's return, the addition to tax for negligence or the
intentional disregard of rules or regulations is not applicable.
Sec. 6664(c); Weis v. Commissioner, 94 T.C. 473, 487 (1990). To
show good faith reliance, the taxpayer must show that the return
preparer was supplied with all the necessary information and the
incorrect return was a result of the preparer's mistakes. Pessin
v. Commissioner, 59 T.C. 473, 489 (1972).
After careful review, we conclude that petitioner did not
provide Mr. Stoller with all of the necessary information to
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