Quantum Company Trust - Page 20




                                       - 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.                                     




















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