Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 30




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          the return or in a statement attached to the return.  See sec.              
          6662(d)(2)(B).                                                              
               The accuracy-related penalty does not apply with respect to            
          any portion of the underpayment if it is shown that there was               
          reasonable cause for such portion and that the taxpayer acted in            
          good faith.  See sec. 6664(c)(1).  The determination of whether a           
          taxpayer acted with reasonable cause and in good faith depends              
          upon the pertinent facts and circumstances, including the                   
          taxpayer’s efforts to assess his or her proper tax liability, the           
          knowledge and experience of the taxpayer, and reliance on the               
          advice of a professional, such as an accountant.  See sec.                  
          1.6664-4(b)(1), Income Tax Regs.                                            
               Petitioners contend they had a good faith belief that they             
          were entitled to take the $8 million bad debt deduction on their            
          1989 tax return based on discussions with their return preparers.           
          They claim that they relied on the professional advice of the               
          preparers, and the decision to take the deduction was Mr.                   
          Johnson’s.  Petitioners further contend that they disclosed all             
          relevant facts to the preparers.                                            
               Generally the duty of filing accurate returns cannot be                
          avoided by placing the responsibility on a tax return preparer.             
          See Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662 (1987).              
          While hiring an attorney or accountant does not insulate the                
          taxpayer from negligence penalties, good faith reliance on                  







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