- 3 - reasonable cause and in good faith depends upon the facts and circumstances. See sec. 1.6664-4(b)(1), Income Tax Regs. Reliance on the advice of an accountant may demonstrate reasonable cause and good faith. See sec. 1.6664-4(b)(1), Income Tax Regs. Petitioner contends that it complied with all record-keeping obligations, provided Ford Motor Company Dealer Financial Statements to the accountant, had other records available for review, and relied in good faith on the advice of the accountant. Petitioner, however, did not provide its accountant with sufficient information from which an accurate return could be prepared. Under such circumstances, reliance on an accountant’s advice is not in good faith and does not establish that the taxpayer acted with reasonable cause. See Estate of Monroe v. Commissioner, 104 T.C. 352, 366-367 (1995). Accordingly, petitioner is liable for accuracy-related penalties relating to 1993 and 1994. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3
Last modified: May 25, 2011