Paul Trans and Thuy Bich Dang - Page 24




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               Apart from passing references in petitioner husband's                  
          testimony to his tax preparer, the record is devoid of evidence             
          to support petitioners' contentions.  Petitioners did not call              
          their tax preparer as a witness.  There is no evidence to support           
          a determination that petitioners acted reasonably or in good                
          faith in relying on their tax preparer’s advice, or indeed any              
          evidence as to what qualifications their tax preparer might have            
          had.  There is no evidence that petitioners disclosed to their              
          tax preparer all relevant facts and circumstances, or that the              
          advice was based on reasonable factual or legal assumptions.                
               Accordingly, we sustain the imposition of the accuracy-                
          related penalty under section 6662(a) for all years in issue.               
               To reflect concessions and the foregoing,                              

                                             Decision will be entered                 
                                        under Rule 155.                               




















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