- 50 - We have found that petitioner was not aware of the errors relating to the disallowed automobile expenses that Mr. McVeigh made in Schedules C of petitioner's 1989, 1990, and 1991 returns relating to Psychological Testing Services and that he could not have detected them by reviewing those returns. On the record before us, we find that petitioner's reliance on Mr. McVeigh with respect to the claimed disallowed automobile expenses in petitioner's returns for the years at issue was reasonable and in good faith. Consequently, we reject respon- dent's determinations imposing the accuracy-related penalty on the portion of the underpayment for each such year that is attributable to those disallowed expenses. Substantial Understatement of Income Tax Petitioner's Claimed Deductions of Losses From His Horse Activity and His Cattle Activity We have found that, based on what petitioner told Mr. McVeigh about his horse activity and his cattle activity, includ- ing that he intended to buy, train, and sell horses34 and that he had incurred certain expenses for various stables and training centers that Mr. McVeigh believed to be reputable, Mr. McVeigh concurred in petitioner's conclusion, and he and petitioner jointly decided, that the gross income, expenses, and loss from 34 We note that this finding is based on Mr. McVeigh's testimony as to what petitioner told him about his intention with respect to his horse activity.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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