- 15 - have put the taxpayer on notice that he was not backing the advice embodied in the return), affd. 992 F.2d 1132 (11th Cir. 1993). Respondent contends that petitioner did not have substantial authority or reasonable cause for its minimum expensing position because petitioner’s chief financial officer, Pamela Rau (Rau), did not discuss the deductibility of the disputed assets with petitioner’s tax return preparer for 1995 and 1996. We disagree. Rau reasonably explained that she did not discuss petitioner’s expensing policy with the preparer because petitioner’s expensing policy in 1995 and 1996 was the same as it had been in previous years. Petitioner's reliance on its preparer was reasonable cause for expensing the disputed assets in 1995 and 1996. We hold that petitioner is not liable for the accuracy- related penalty under section 6662 for 1995 and 1996. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011