-22-
Commissioner, 414 F.2d 749, 750 (4th Cir. 1969), affg. T.C. Memo.
1968-98; Otis v. Commissioner, 73 T.C. 671, 675 (1980).
Richardson was fully aware of the facts about petitioner's
residence and Broadmoor Gardens. Petitioner's reliance on
Richardson to prepare accurately her 1990 and 1991 returns was
reasonable. Thus, we hold that petitioner is not liable for the
accuracy-related penalty for 1990 and 1991.
To reflect the foregoing,
An appropriate order
will be issued.
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