- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011