- 27 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
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