Chen C. and Victoria R. Wang, et al. - Page 41

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          hiring an attorney or accountant does not insulate the taxpayer             
          from negligence penalties, good faith reliance on professional              
          advice concerning tax laws is a defense.  United States v. Boyle,           
          469 U.S. 241 (1985); Betson v. Commissioner, 802 F.2d 365, 372              
          (9th Cir. 1986), affg. in part and revg. in part T.C. Memo. 1984-           
          264.  Reliance on a qualified adviser may demonstrate reasonable            
          cause and good faith if the evidence shows that the taxpayer                
          contacted a competent tax adviser and provided the adviser with             
          all necessary and relevant information.  Collins v. Commissioner,           
          857 F.2d 1383, 1386 (9th Cir. 1988), affg. Dister v. Commis-                
          sioner, T.C. Memo. 1987-217; Jackson v. Commissioner, 86 T.C.               
          492, 539-540 (1986), affd. 864 F.2d 1521 (10th Cir. 1989).  In              
          order to prove such reliance, the taxpayer must establish that              
          the return preparer was supplied with all necessary information,            
          and the incorrect return was the result of the preparer's mis-              
          takes.  Weis v. Commissioner, 94 T.C. 473, 487 (1990).                      
               Respondent contends that all of the deficiencies were due to           
          negligence, disregard of the rules or regulations, or a substan-            
          tial understatement of income tax.  Petitioner and EIC provided             
          evidence of discussions that were held with their accountants               
          regarding the proper accounting method to be used by them.  With            
          regard to the remaining items, such as the reasonable compensa-             
          tion, constructive dividends, and numerous concessions by                   
          petitioners, the record is silent as to what information peti-              





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