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petitioners, which began around 1977 or 1978. Mr. Plante credibly
testified that petitioners sought his advice in order to fulfill
their tax obligations in the United States. It is well documented
in the record that petitioners relied upon the advice of Mr. Plante.
It is obvious that Mr. Plante possessed sufficient expertise in
the field of tax law, and we believe that, with the exception of the
issue concerning the deduction claimed by Powertex for consulting
fees paid to SCS, petitioners provided him with the necessary and
relevant information to prepare their tax returns. After a careful
review of the record, we hold that, based on all the facts and
circumstances, except as to the SCS consulting fees issue,
petitioners reasonably relied in good faith on the advice of Mr.
Plante and are therefore not liable for the penalties and additions
to tax as determined by respondent.
As to the SCS consulting fees issue, we hold that petitioners
have not met the requirements of the reasonable cause exception that
are necessary to avoid imposition of the section 6662(a) accuracy-
related penalty. If a taxpayer relies reasonably and in good faith
upon the advice of a competent and experienced accountant in the
preparation of the taxpayer's return, the penalty for negligence or
the intentional disregard of rules or regulations is not applicable.
Weis v. Commissioner, supra at 487. To show good faith reliance,
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