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provided correct and complete information to an adviser who has
expertise regarding the tax ramifications of the transactions
involved. See Collins v. Commissioner, 857 F.2d 1383, 1386 (9th
Cir. 1988), affg. Dister v. Commissioner, T.C. Memo. 1987-217.
Here petitioner has failed to make that showing. We conclude
that petitioner is liable for the accuracy-related penalties for
the years in issue.
In view of the foregoing,
Decision will be entered
under Rule 155.
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