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reasonable cause for its deduction of the excessive
compensation.
To avoid liability for the addition to tax, petitioner
further argues that it relied on the advice of its accountant,
West. Reliance upon the advice of an attorney or accountant
constitutes a showing of reasonable cause and good faith only if
it was reasonable to rely on the advice under the circumstances.
Vorsheck v. Commissioner, 933 F.2d 757, 759 (9th Cir. 1991);
sec. 1.6661-6(b), Income Tax Regs. For reliance on professional
advice to be reasonable, the taxpayer must supply the accountant
with accurate information and the error in the return must be
due to the accountant's mistake. Metra Chem Corp. v.
Commissioner, 88 T.C. 654, 662 (1987); Ma-Tran Corp. v.
Commissioner, 70 T.C. 158, 173 (1978). The experience and
sophistication of the taxpayer affect the reasonableness of its
reliance on a professional. Vorsheck v. Commissioner, supra at
759.
In this case, Kleindienst, petitioner's representative, is
a sophisticated and experienced businesswoman well aware of the
prior audit and the uncertainty of the legality of the
compensation deduction for taxable year ended July 31, 1987.
Kleindienst not only participated in the compensation
determination but also had the final authority to set her own
compensation. Petitioner did not prove that the deficiency
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