Cordes Finance Corporation - Page 30

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                of Mr. Cordes as repossession costs.  Mr. Hinman was the                                 
                only member of petitioner's firm of outside certified                                    
                public accountants to testify at trial.  Moreover, none of                               
                petitioner's employees who testified at trial attributed                                 
                the errors in petitioner's return to advice received from                                
                its accountants.  Therefore, we reject petitioner's                                      
                contention that it acted with reasonable cause and in good                               
                faith.                                                                                   
                      We also reject petitioner's contention that the                                    
                accuracy-related penalty should not be imposed because                                   
                there was no underpayment.  As discussed above in                                        
                connection with the fraud penalty, petitioner cites no                                   
                authority for its contention that the underpayment in this                               
                case must be determined "exclusive of the accounting change                              
                issue".  The definition of underpayment contained in                                     
                section 6664(a) and the regulations promulgated thereunder,                              
                section 1.6664-2(a), Income Tax Regs., requires otherwise.                               
                      In light of the foregoing and concessions by the                                   
                parties,                                                                                 

                                                           Decision will be entered                      
                                                     under Rule 155.                                     










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