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Furthermore, reliance upon the advice of an expert tax
preparer may, but does not necessarily, demonstrate reasonable
cause and good faith in the context of the section 6662(a)
penalty. See id.; see also Freytag v. Commissioner, supra at
888. Such reliance is not an absolute defense, but it is a
factor to be considered. See Freytag v. Commissioner, supra at
888. In order for this factor to be given dispositive weight,
the taxpayer claiming reliance on a professional must show, at
minimum, that (1) the preparer was supplied with correct
information and (2) the incorrect return was a result of the
preparer’s error. See, e.g., Westbrook v. Commissioner, 68 F.3d
868, 881 (5th Cir. 1995), affg. T.C. Memo. 1993-634; Cramer v.
Commissioner, 101 T.C. 225, 251 (1993), affd. 64 F.3d 1406 (9th
Cir. 1995); Ma-Tran Corp. v. Commissioner, 70 T.C. 158, 173
(1978); Pessin v. Commissioner, 59 T.C. 473, 489 (1972); Garcia
v. Commissioner, T.C. Memo. 1998-203, affd. without published
opinion 190 F.3d 538 (5th Cir. 1999).
The notice of deficiency issued to petitioners asserted
applicability of the section 6662(a) penalty on account of both
negligence and/or substantial understatement. (The notice also
referenced substantial valuation overstatement as an additional
alternative ground, see sec. 6662(b)(3), but since valuation was
not a focus of this case, we disregard the apparent boilerplate
reference.) Petitioners seek to avoid this penalty on the basis
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