Allied Marine Systems, Inc. - Page 23

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          taxpayer was reasonable and the taxpayer acted in good faith.               
          Id.                                                                         
               Based on the record, we conclude that petitioner is not                
          liable for the section 6662 accuracy-related penalty on the                 
          portion of the underpayment related to the Solomons house.                  
          Petitioner retained Sherwood to prepare his 1989 return and both            
          petitioner's and Sherwood's testimony indicated that petitioner             
          provided Sherwood with all of the information regarding the                 
          Solomons house.  Although petitioner's reliance on Sherwood in              
          this regard was misplaced, we do not conclude that petitioner's             
          reliance on Sherwood was unreasonable.                                      
               Petitioner has not shown reasonable cause or good faith for            
          the remainder of the underpayment.  Neither petitioner nor                  
          Sherwood testified as to what information petitioner provided to            
          Sherwood regarding Allied's payment of petitioner's personal                
          expenses.  Thus, the section 6662(a) penalty will be sustained as           
          to the remaining portion of the underpayment for 1989.                      
               To reflect the foregoing and concessions of the parties,               
                                                  Decisions will be entered           
                                             under Rule 155.                          












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