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part and revg. in part a Memorandum Opinion of this Court;
Haywood Lumber & Mining Co. v. Commissioner, 178 F.2d 769,
771 (2d Cir. 1950), modifying 12 T.C. 735 (1949); Orient
Inv. & Fin. Co. v. Commissioner, 166 F.2d 601, 603-604
(D.C. Cir. 1948); Furman v. Commissioner, T.C. Memo. 1998-
157.
The only argument made by respondent regarding
petitioners' reliance on their accountants is the
following:
Petitioners cannot simply lay the blame
on accountants or bookkeepers for failing to
obtain the information necessary to make a proper
estimate. "It is the taxpayer's obligation to
supply his or her accountant with complete and
accurate records from which to make a reasonable
estimate of the tax liability." Boatman v.
Commissioner, T.C. Memo. 1995-356 (citing Estate
of Duttenhofer v. Commissioner, 49 T.C. 200, 205
(1967), aff'd, 410 F.2d 302 (6th Cir. 1969)).
Neither can petitioners avoid the I.R.C. � 6651
(a)(1) penalty by attempting to lay the blame
on a representative for failing to timely file
a return. "To demonstrate reasonable reliance,
it must be shown that the advisor had sufficient
knowledge of the taxpayer's relevant financial
circumstances to make an informed decision."
Stovall v. Commissioner, T.C. Memo. 1983-450
(citing Yale Avenue Corp. v. Commissioner, 58
T.C. 1062 (1972) and Railroad Realty Co. v.
Commissioner, 25 T.C. 458 (1955)).
We find no support in the record for respondent's argument.
Petitioners' accountants had a longstanding relationship
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