Arlan L. Rower and Sandra M. Howard - Page 24

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          can Properties, Inc. v. Commissioner, 28 T.C. 1100, 1116-1117               
          (1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958).  Reliance            
          on a professional adviser, standing alone, is not an absolute               
          defense to negligence; it is only one factor to be considered.              
          Freytag v. Commissioner, supra at 888.  In order for reliance on            
          a professional adviser to excuse a taxpayer from the accuracy-              
          related penalty for negligence, the taxpayer must establish that            
          the professional adviser on whom he or she relied had the exper-            
          tise and knowledge of the relevant facts to provide informed                
          advice on the subject matter.  See id.                                      
               Contrary to petitioners' contention that they have shown               
          that they "took great care in keeping records", we have found               
          that there is no evidence in the record to establish (1) when any           
          documents that are part of the record and that are, or purport to           
          be, petitioners' records were prepared and (2) whether any such             
          documents are complete and accurate.  With respect to petition-             
          ers' contention that they have shown that all of the deductions             
          that respondent disallowed in the notice are "legal, justified,             
          and proven", we have found that they have not established that              
          they are entitled to those deductions.                                      
               With respect to any contention by petitioners that they                
          should not be liable under section 6662(a) because they relied on           
          Mr. Grenville-Jones, who prepared their 1993 return (as well as             







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