- 16 - Here, Ms. Burkes' situation was very complex in that her 1990 reporting year contained a transitional situation where the amount reportable was changing and the amounts that were or were not reportable were subject to some doubt. In this situation, Ms. Burkes reasonably relied on her attorney and the accountant selected for her by the attorney. There were substantial legal questions as to which of the numerous items were reportable as alimony. These circumstances made it reasonable for Ms. Burkes to rely on the advice of the two professionals involved. We conclude that Ms. Burkes was therefore not negligent within the meaning of section 6662 for her 1990 taxable year. On brief, Mr. Burkes did not make any argument concerning respondent's determination concerning the section 6662(a) penalties. We treat this omission as a concession that, to the extent not conceded by respondent, Mr. Burkes is liable for the section 6662(a) penalties as determined. To reflect the foregoing and to account for agreements and concessions of the parties, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011