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Contractors, Inc. v. Commissioner, supra, we find there
was no negligence or disregard of rules or regulations
on the part of * * * [the taxpayer]. [Id. at 183.]
We believe that for the same reason, petitioners herein
should be relieved of the section 6662 penalties. Petitioners’
tax returns for the years in dispute were filed prior to our
opinion in Hood v. Commissioner, supra, which was filed in the
year 2000, and petitioners’ tax return preparer would have had
access to the same authority that the taxpayers in Hood had
access to. In light of our holding in Hood v. Commissioner,
supra, we do not impose upon petitioners herein the accuracy-
related penalties relating to the disallowed legal fees paid by
Capital Video and relating to the additional dividend and income
adjustments made against Guarino. We so hold.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011