- 42 -
tioner may have provided to his accountants, or what advice the
accountants may have given petitioner. Accordingly, petitioner
and EIC have failed to establish that they relied on any advice
with respect to the remaining items. Where no reliable evidence
exists in the record suggesting the nature of any advice given by
a preparer, we may conclude that the taxpayers have failed to
carry their burden in proving good faith reliance on that
preparer. See Howard v. Commissioner, 931 F.2d 578, 582 (9th
Cir. 1991), affg. T.C. Memo. 1988-531; Skeen v. Commissioner, 864
F.2d 93, 96 (9th Cir. 1989), affg. Patin v. Commissioner, 88 T.C.
1086 (1987). Consequently, we sustain respondent's imposition of
the accuracy-related penalties on the portion of the underpayment
attributable to these items for each of the years at issue.
Petitioner presented evidence of discussions that were held
concerning the election of the installment method. Petitioner's
accountant from Arthur Andersen & Co. testified about his reasons
for selecting the installment method. He indicated that peti-
tioner was forthcoming with all necessary information. On the
basis of this information, petitioner's accountant advised
petitioner to report income from land sales on the installment
method. Petitioner is not a tax expert, and he relied on his
accountants for this type of advice. Selecting an accounting
method is a sufficiently technical issue, and reliance on the
advice of an expert is reasonable under these circumstances. See
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