- 54 - check. Russell testified that he thought Mr. Feldmann was aware of any reimbursements for the drilling costs when the oil and gas information was provided to him. Russell has not shown that there was reasonable cause for the underpayment attributable to the overstated IDC deduction and that the he acted in good faith with respect to the underpayment. Russell was aware that a portion of IDCs might be reimbursed to him, yet he did not take steps to inquire as to whether any amount was reimbursed to him in 1995. In the instant situation, he cannot avoid his duty to file an accurate tax return by placing the responsibility with Carolyn to provide Mr. Feldmann with the correct information regarding the amount of IDCs. Accordingly, we hold that Russell and Clarice are liable for the accuracy-related penalty on the portion of the underpayment attributable to the IDC adjustment. With respect to the Schedule C production tax deduction, Mr. Feldmann testified that he would have calculated this based on the information he received from Russell’s family or Melvin’s family. Russell’s only claim with respect to this adjustment is that he reasonably relied on the advice of Mr. Feldmann. He has not shown that all necessary information was supplied to Mr. Feldmann and that the overstated deduction resulted from Mr. Feldmann’s mistake. Russell and Clarice have not established that they had reasonable cause or good faith with respect to thisPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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