PMT, INC. - Page 36

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               Section 6662(d)(2)(B) states that the amount of the                    
          understatement shall be reduced by the portion of the                       
          understatement which is attributable to the tax treatment of any            
          item if there is or was substantial authority for such treatment            
          or if the relevant facts affecting the item's tax treatment are             
          adequately disclosed on the return or in a statement attached to            
          the return and there is a reasonable basis for the tax treatment            
          of such item.  To determine whether the treatment of any portion            
          of an understatement is supported by substantial authority, the             
          weight of authorities in support of the taxpayer's position must            
          be substantial in relation to the weight of authorities                     
          supporting contrary positions.  Antonides v. Commissioner, 91               
          T.C. 686, 702-703 (1988), affd. 893 F.2d 656 (4th Cir. 1990).               
               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 is reasonable and the taxpayer acted           
          in good faith.  Sec. 1.6661-6(b), Income Tax Regs.                          
               We hold that petitioner acted with reasonable cause.  Mr.              
          and Mrs. Penalba relied on the advice of their accountant, Mr.              
          Blumberg, both in determining the salaries for the year at issue            
          and establishing the bonus plan.  Mr. Blumberg was under the                




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