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only a factor to be considered. Ewing v. Commissioner, 91 T.C.
396, 423-424 (1988), affd. without published opinion 940 F.2d
1534 (9th Cir. 1991). Reliance on a return preparer may
demonstrate reasonable cause and good faith if the evidence in
the record shows that the taxpayer actually relied on a competent
tax adviser and provided the adviser with all necessary and
relevant information. Daugherty v. Commissioner, 78 T.C. 623,
641 (1982); Pessin v. Commissioner, 59 T.C. 473, 489 (1972);
Tebarco Mechanical Corp. v. Commissioner, T.C. Memo. 1997-311.
Mr. Ciaravella claims that he relied on the advice of Mr.
Buchman, a return preparer, in setting up Innovative and claiming
deductions for the race car expenditures. Mr. Buchman did not
testify at the trial, nor was there any other evidence of any
particular advice he may have given to Mr. Ciaravella. Neither
did Mr. Ciaravella testify as to any particular advice he
received from Mr. Buchman. Accordingly, we find insufficient
evidence that Mr. Ciaravella relied on the advice of a return
preparer, and we sustain respondent's imposition of the accuracy-
related penalty under section 6662(a).
To reflect the foregoing and respondent's concessions,
Decisions will be entered under
Rule 155.
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