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Petitioner has established that he was involved in an active
trade or business activity. With respect to the claimed
deductions, petitioner provided detailed expense accounts records
and credible testimony. Petitioner testified that he relied on
his accountant to prepare his 1993 tax return, as petitioner had
done in previous years. Reliance on an accountant to prepare tax
returns is not sufficient by itself to establish reasonable
cause. See Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662
(1987). The taxpayer must also show that he supplied the tax
preparer with complete and accurate information sufficient to
properly prepare the return, that the incorrect return was the
result of the tax preparer’s mistakes, and that the taxpayer in
good faith relied on the advice of a competent tax preparer. See
Pessin v. Commissioner, 59 T.C. 473, 489 (1972).
While petitioner may have provided his accountant with
detailed records, the expenses listed in the records were not
allowable as business deductions. Petitioner has not alleged
that his accountant made any mistakes in preparing petitioner’s
1993 tax return. Additionally, petitioner’s insistence that he
is still the owner of the rental equipment is troubling in light
of the substantial evidence to the contrary. Based on the
evidence in the record, petitioner has failed to demonstrate
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