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Commissioner, 51 T.C. 467, 475 (1968); sec. 1.6664-4(b)(1) and
(2), Example (1), Income Tax Regs. To show good faith reliance,
the taxpayer must show that the return preparer was supplied with
all the necessary information and the incorrect return was the
result of the preparer's mistakes. Pessin v. Commissioner, 59
T.C. 473, 489 (1972); Enoch v. Commissioner, 57 T.C. 781, 803
(1972).
Petitioner retained a certified public accountant to prepare
his 1992 return and advise him as to the deductibility of the
payments made to or on behalf of his former spouse pursuant to
the Judgment. Tomlin had been petitioner's accountant for 16
years, and petitioner relied on him to complete the return
accurately. Petitioner supplied Tomlin with all of the records
in his possession pertaining to the payments to his former
spouse, including the Judgment. In addition, petitioner spoke
with Indictor, an attorney and former employee of the IRS, about
the deductibility of the payments several times before completing
his 1992 return. Based on this record, even though we have found
that petitioner's reliance on Tomlin and Indictor was misplaced,
we find that petitioner acted with reasonable cause and good
faith in attempting to comply with the provisions of the Internal
Revenue Code. We hold, therefore, that petitioner is not liable
for the section 6662(a) accuracy-related penalty determined by
respondent. See Rosenthal v. Commissioner, T.C. Memo. 1995-603;
Conway v. Commissioner, T.C. Memo. 1994-405.
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