Estate of Alton Bean - Page 11




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            were negligent.  Negligence, in the present context, reflects                              
            taxpayers' failure to make reasonable attempts to comply with the                          
            Internal Revenue Code.  See sec. 6662(c).                                                  
                  Accuracy-related penalties may be avoided if taxpayers show                          
            that the errors were caused, in some significant part, by                                  
            detrimental reliance on the advice of qualified tax professionals                          
            and that their reliance was reasonable and in good faith.  See                             
            sec. 6664(c); United States v. Boyle, 469 U.S. 241, 250 (1985);                            
            Stanford v. Commissioner, 152 F.3d 450, 460-461 (5th Cir. 1998),                           
            affg. in part and vacating on this issue 108 T.C. 344 (1997).                              
                  Petitioners employed an accountant to prepare their tax                              
            returns for the years in issue.  Having considered petitioners'                            
            and the accountant's testimony, we conclude that petitioners                               
            reasonably relied on the accountant to ascertain their tax bases                           
            in the indebtedness of the Corporation.  We do not sustain                                 
            respondent's imposition of the accuracy-related penalties.                                 
                  To reflect the foregoing,                                                            
                                                      Decisions will be entered for                    
                                                respondent as to the deficiency                        
                                                amounts and for petitioners as to                      
                                                the accuracy-related penalties.                        











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