- 24 -
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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