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would do under the same circumstances. Neely v. Commissioner, 85
T.C. 934 (1985).
No penalty shall be imposed under section 6662(a) with
respect to any portion of an underpayment if it is shown that
there was reasonable cause and that the taxpayer acted in good
faith. Sec. 6664(c). Whether a taxpayer acted with good faith
depends upon the facts and circumstances of each case. Sec.
1.6664-4(b)(1), Income Tax Regs. Reliance on the advice of a
professional tax adviser or return preparer constitutes
reasonable cause and is in good faith if the taxpayer
establishes, among other things, that the taxpayer provided the
adviser or return preparer with the necessary and accurate
information. Neonatology Associates P.A. v. Commissioner, 115
T.C. 43, 99 (2000). If the taxpayer fails to provide the adviser
or return preparer with the information necessary for preparing
the return, the taxpayer may be liable for the penalty. Johnson
v. Commissioner, 74 T.C. 89, 97 (1980), affd. 673 F.2d 262 (9th
Cir. 1982).
We have found that petitioners underreported their capital
gain on the redemption of Tony’s CRC stock by $116,831. They
have offered no explanation for the $159,100 sale price reported
on their 1992 Federal income tax return–-an amount less than the
$166,831 that CRC reported on the Form 1099–-or the $109,100
basis they claimed for the CRC stock. Petitioners claimed net
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