- 30 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011