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necessarily demonstrate reasonable cause and good faith. Sec.
1.6664-4(b)(1), Income Tax Regs. Where the taxpayer claims
reliance on an accountant who prepared the return, the taxpayer
must establish that the correct information was provided to the
accountant and that the item incorrectly claimed or reported in
the return was the result of the accountant's error. Ma-Tran
Corp. v. Commissioner, 70 T.C. 158, 173 (1978); Enoch v.
Commissioner, 57 T.C. 781, 803 (1972).
Mr. Haymond and Mr. Strong, an experienced C.P.A., discussed
the sale of the stock, and Mr. Haymond provided him with the
resolution. Mr. Strong knew the commission had not been paid
and that InTex used the cash method of accounting. It was not at
Mr. Haymond's instruction, but rather on Mr. Strong's own
initiative, that the commission was treated as part of the basis
of the Bonneville Pacific stock.
We find that petitioners provided Mr. Strong with sufficient
information and that their reliance on Mr. Strong was reasonable
and in good faith. We think that the question of includability
of the commission obligation was sufficiently technical so that
neither Mr. Haymond (and a fortiori, Mrs. Haymond) could have
been expected to dispute Mr. Strong's treatment. See United
States v. Boyle, 469 U.S. 241, 251 (1983) ("Most taxpayers are
not competent to discern error in the substantive advice of an
accountant or an attorney"); cf. Olsen Associates, Inc. v. United
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