- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011