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reasonable cause and if petitioner acted in good faith. Sec.
6664(c).
The participation of highly paid professionals provides
petitioner no protection, excuse, justification, or immunity from
the penalties in issue. Petitioner participated in a clear and
obvious scheme to reap the benefits of claimed ordinary business
expense deductions that had no business purpose and no economic
substance. The facts and circumstances of this case reflect no
reasonable cause and no good faith for petitioner’s participation
in the transactions before us.
Petitioner is liable for the accuracy-related penalties
under section 6662(a).
To reflect the foregoing,
Decision will be entered
for respondent.
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