Pine Creek Farms, Ltd. - Page 10




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          Income Tax Regs.  Reliance on the advice of an accountant may               
          demonstrate reasonable cause and good faith.  United States v.              
          Boyle, 469 U.S. 241, 250-151 (1985); sec. 1.6664-4(b)(1), Income            
          Tax Regs.                                                                   
               In this case, the tax consequences regarding the futures               
          transactions and the ownership of the various corporations were             
          fairly complex.  Petitioner's tax returns were prepared by its              
          accountant.  Petitioner relied upon the accountant's advice.  We            
          find that petitioner had reasonable cause for the underpayment of           
          tax and acted in good faith.  Accordingly, we hold for petitioner           
          as to the section 6662(a) penalty.                                          


                                                  Decision will be entered            
                                             for respondent as to the                 
                                             deficiency and for petitioner            
                                             as to the penalty.                       



















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