Srichai and Pusadee Rungrangsi - Page 19

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               Section 6662 imposes an accuracy-related penalty equal to 20           
          percent of the portion of the underpayment attributable to                  
          negligence or disregard of rules or regulations.  "Negligence"              
          means any failure to make a reasonable attempt to comply with the           
          provisions of the Internal Revenue Code, and "disregard" means any          
          careless, reckless, or intentional disregard.  Sec. 6662(c); see            
          also Neely v. Commissioner, 85 T.C. 934, 947 (1985).                        
               No accuracy-related penalty is imposed with respect to any             
          portion of the understatement in which the taxpayer acted with              
          reasonable cause and in good faith.  Sec. 6664(c)(1).                       
               Mr. Rungrangsi testified that he relied on his accountants in          
          preparing the tax returns for the years in issue.  However, he did          
          not establish that he provided his accountants with all the                 
          information necessary for them to prepare petitioners' returns              
          properly.  Petitioners' accountants did not testify at trial, and           
          the parties stipulated that petitioners did not have any books or           
          records reflecting the income or expenses of Stanton Mexicatessen           
          for the years in issue.                                                     
               Reliance on an accountant to prepare tax returns is not                
          sufficient by itself to establish reasonable cause.  See Metra Chem         
          Corp. v. Commissioner, 88 T.C. 654, 662 (1987).  The taxpayer must          
          also show that he supplied the tax preparer with complete and               
          accurate information so that the return could be properly prepared,         
          an incorrect return was the result of the tax preparer's mistakes,          

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