- 8 - reasonable cause for the underpayment and that the taxpayer acted in good faith. The determination of whether a taxpayer acted with reasonable cause and in good faith depends upon the facts and circumstances. See sec. 1.6664-4(b)(1), Income Tax Regs. Reliance on the advice of an accountant may demonstrate reasonable cause and good faith. See id. Respondent concedes that petitioner is not liable for the 1994 accuracy-related penalty, but contends that “petitioner has failed to substantiate even a third of the expenditures at issue in this case.” We conclude that petitioner reasonably and in good faith relied on his accountants. Accordingly, he is not liable for the 1995 and 1996 accuracy-related penalties. Contentions we have not addressed are moot, irrelevant, or meritless. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011