- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011