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No accuracy-related penalty is imposed with respect to any
portion of the understatement as to which the taxpayer acted with
reasonable cause and in good faith. Sec. 6664(c)(1).
At trial, when questioned about discrepancies between figures
in the tax returns and the amounts the parties stipulated, Mohan
Roy claimed that he relied on his accountant to prepare the Federal
tax returns--presumably referring to both the corporate and
personal returns. However, reliance on an accountant to prepare
tax returns is not sufficient by itself to establish reasonable
cause. See Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662
(1987). The taxpayer must also show that: (1) The taxpayer
provided the return preparer with complete and accurate information
from which the tax return could be properly prepared; (2) an
incorrect return was the result of the preparer's mistakes; and (3)
the taxpayer in good faith relied on the advice of a competent tax
return preparer. Jackson v. Commissioner, 86 T.C. 492, 539-540
(1986), affd. 864 F.2d 1521 (10th Cir. 1989); Hotel Continental,
Inc. v. Commissioner, T.C. Memo. 1995-364, affd. without published
opinion 113 F.3d 1241 (9th Cir. 1997).
Both the corporate and the individual petitioners have failed
to prove that they acted with reasonable cause and in good faith.
Rule 142(a). Thus, we hold that the corporate petitioner is liable
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