Estate of Dorothy Morganson Schauerhamer, Deceased, Karl C. Dean, Personal Representative - Page 11

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          professional accountants, attorneys, and appraisers in preparing            
          the returns.  In essence, petitioner contends that any                      
          understatements of tax were in good faith and due to reasonable             
          cause.  See sec. 6664(c).                                                   
               The regulations state that whether an underpayment of tax is           
          made in good faith and due to reasonable cause will depend upon             
          the facts and circumstances of each case.  Sec. 1.6664-4(b),                
          Income Tax Regs.  Reliance on the advice of a professional will             
          constitute good faith and reasonable cause only where such                  
          reliance was reasonable.  Id.  We conclude that petitioner acted            
          reasonably and in good faith in relying on the advice of tax                
          professionals and property appraisers.  As a result, petitioner             
          is not liable for the accuracy-related penalty for negligence.              
               We have considered all other arguments made by the parties             
          and found them to be either irrelevant or without merit.                    
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          















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