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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.
Petitioner contends that the accuracy-related penalty is
inappropriate in this case, because it relied on its certified
public accountant, Michael Powers, to prepare its tax return
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
(10th Cir. 1989); Daugherty v. Commissioner, 78 T.C. 623, 641
(1982); Magill v. Commissioner, 70 T.C. 465, 479 (1978), affd.
651 F.2d 1233 (6th Cir. 1981); Pessin v. Commissioner, 59 T.C.
473, 489 (1972).
At trial, Powers testified that he had prepared petitioner's
tax returns from the time of its inception in 1983, and that
subcontractors similar to petitioner comprised approximately 50
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