- 11 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011