- 9 - Petitioner is a lineman for the power company, and his wife is a brusher with a furniture company. They are not sophisticated with respect to financial matters. Petitioners’ returns were prepared by a professional tax return preparer. We have recognized that reliance on the advice of a professional is a factor to be considered in determining whether a taxpayer uses reasonable care. See id. at 888. Moreover, while we conclude that the Schedule C losses are not deductible because the activity was not entered into for profit, there are factors that may be viewed as being favorable to petitioners. Accordingly, we do not sustain the section 6662(a) penalties. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011