- 20 - We believe that the Nortons have sustained their burden of establishing reasonable cause and good faith. Numerous deductions disallowed by respondent in his notice of deficiency were subsequently conceded fully or in large measure by respondent. The Nortons were not tax sophisticated. As a result, they actively sought assistance in determining their tax liability. Although some of that advice was inaccurate, we accept Mr. Norton’s testimony that they reasonably relied upon the advice of two attorneys as well as their tax preparer in reporting their income and expenses. Moreover, there is nothing in the record to indicate that the Nortons’ conduct was negligent or undertaken in reckless disregard of applicable Code sections. Accordingly, we hold that the Nortons are not liable for the accuracy-related penalty. In reaching our conclusions herein, we have considered all arguments presented and, to the extent not discussed above, find them to be irrelevant or without merit.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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