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apply to any portion of an 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 on 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 the reliance on the
advice of a professional, such as an accountant. See sec.
1.6664-4(b)(1), Income Tax Regs.
Based on our examination of the entire record before us, we
find that Mr. Mitic, who listed his occupation in both the 1993
and 1994 joint returns as “Accountant”, has failed to establish
that petitioners are not liable for the years at issue for the
accuracy-related penalties under section 6662(a).10
We have considered all of the arguments of Mr. Mitic that
are not discussed herein, and we find them to be without merit
and/or irrelevant.
To reflect the foregoing and the concessions of the
parties,11
10The amount of the accuracy-related penalty for which
petitioners are liable for each of the years at issue shall be
determined in the Rule 155 computations by taking into account
the concessions of the parties in the first stipulation of
settled issues filed in this case.
11After Rule 155 computations have been submitted, we shall
grant respondent’s motion and enter a decision with respect to
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