-56-
prepared by reputable certified public accountants to whom they
disclosed all relevant facts.
Section 6662(a) imposes a penalty in an amount equal to 20
percent of the portion of the underpayment of tax attributable to
one or more of the items set forth in subsection (b). The
accuracy-related penalty does not apply with respect to any
portion of the underpayment if it is shown that there was
reasonable cause for such portion and that the taxpayer acted in
good faith with respect to such portion. Sec. 6664(c)(1). The
determination of whether a taxpayer acted with reasonable cause
and in good faith is made on a case-by-case basis, taking into
account all the pertinent facts and circumstances. Sec. 1.6664-
4(b)(1), Income Tax Regs. The most important factor is the
extent of the taxpayer's effort to assess its proper tax
liability for the year. Id.
Petitioners contend that the accuracy-related penalty is
inappropriate in this case because they relied on their certified
public accountant, Ricks, to prepare their tax returns
accurately. Generally, the duty of filing accurate returns
cannot be avoided by placing the responsibility on a tax return
preparer. Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662
(1987). However, reliance on a qualified adviser may demonstrate
reasonable cause and good faith if the evidence shows that the
taxpayer relied on a competent tax adviser and provided the
adviser with all necessary and relevant information. Jackson v.
Commissioner, 86 T.C. 492, 539-540 (1986), affd. 864 F.2d 1521
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