- 34 -
unreliable. Either the accountant was not given the relevant
facts and documents, or he ignored them. In any event, in order
for petitioners to prevail on a claim that they reasonably relied
in good faith on a competent return preparer, they must
demonstrate that they supplied all necessary information to the
preparer, they reasonably relied on the preparer’s advice, and
the incorrect returns resulted from the preparer’s mistakes. See
Weis v. Commissioner, 94 T.C. 473, 487 (1990) (dealing with the
addition to tax for negligence under section 6653). Petitioners
have failed to satisfy their burden of proof on this issue.
Conclusion
We have considered carefully all remaining arguments made by
petitioners for a result contrary to that expressed herein, and,
to the extent not discussed above, we find them to be irrelevant,
unnecessary to address, or without merit. We hold on this very
unsatisfying record that petitioners have failed to carry their
burden of proof on any of the alternative arguments presented in
this case.
To reflect the foregoing,
Decisions will be entered
for respondent.
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