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Petitioners contend that they had reasonable cause to take
the position on their return that their police dog training
business was not incorporated in 1990. They contend that they
acted in good faith and relied on Oddo. We disagree. To show
good faith reliance on the advice of a competent adviser, the
taxpayer must show: (1) That he or she gave the return preparer
complete and accurate information, (2) that an incorrect return
was a result of the preparer's mistakes, and (3) that the
taxpayer believed in good faith that he or she was relying on the
advice of a competent return preparer. Metra Chem Corp. v.
Commissioner, 88 T.C. 654, 662 (1987); Pessin v. Commissioner, 59
T.C. 473, 489 (1972).
Petitioners did not give Oddo full details or complete and
accurate information about those transactions. They did not tell
him that they transferred land to Rosewood Kennels, Inc., that it
borrowed $500,000, and that it did business as a corporation in
1990. Thus, they are not entitled to rely on his advice. Metra
Chem Corp. v. Commissioner, supra.
Petitioners rely on Larotonda v. Commissioner, 89 T.C. 287
(1987). The taxpayer in Larotonda reasonably, but erroneously,
assumed that an involuntary assignment of the taxpayer's Keogh
account was not income. That case involved essentially a
technical or legal question. In contrast, the issue here is
essentially factual; i.e., whether petitioners knew that Rosewood
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