- 71 - We believe that petitioners acted with reasonable cause and in good faith in their reliance on Arthur Andersen in connection with the preparation of their returns for the years in issue. Arthur Andersen, an accounting firm having substantial experience in the oil and gas industry, qualifies as a competent tax adviser in the instant case. Moreover, petitioners provided Arthur Andersen with their schedules and workpapers for use in the preparation of their Federal corporate income tax returns. Additionally, Arthur Andersen had access to all of petitioners' books and records. There is nothing in the record to indicate that petitioners withheld any relevant information from Arthur Andersen. Respondent suggests that, because petitioners were short staffed during the years in issue, petitioners devoted less time and resources than usual to their return preparation activities. We disagree. When commitments created by numerous acquisitions left petitioners without the necessary accounting staff required to assist in the preparation of their Federal corporate income tax returns, petitioners engaged a C.P.A. to prepare certain schedules and workpapers for review by Arthur Andersen. Accordingly, we believe that petitioners made significant efforts to assess their proper tax liability. Consequently, we hold that petitioners are not liable for the accuracy-related penalties under section 6662(a) for the years in issue.Page: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 Next
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