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demonstrate reasonable cause if he can show that he relied in
good faith on a qualified adviser after full disclosure of all
necessary and relevant information, see Jackson v. Commissioner,
86 T.C. 492, 539-540 (1986), affd. 864 F.2d 1521 (10th Cir.
1989); Paula Constr. Co. v. Commissioner, 58 T.C. 1055, 1061
(1972), affd. without published opinion 474 F.2d 1345 (5th Cir.
1973); sec. 1.6664-4(b)(1), Income Tax Regs., and that the
incorrect returns resulted from the preparer's error, see Enoch
v. Commissioner, 57 T.C. 781, 803 (1972).
In this case, petitioners have failed to establish that they
fully disclosed all necessary and relevant information to Mr.
Still or that the incorrect returns were a result of Mr. Still's
errors. Thus, petitioners' negligence was not due to reasonable
cause.
Accordingly, we sustain respondent's determination that
petitioners are liable for the accuracy-related penalty under
section 6662(a) for their 1991, 1992, and 1993 taxable years.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011