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2. Reliance on Professionals
A taxpayer may be relieved of liability for the accuracy-
related penalty if he or she shows that there was reasonable
cause for the understatement and that the taxpayer acted in good
faith with respect to the understatement. Sec. 6664(c); sec.
1.6664-4(a), Income Tax Regs. Petitioner contends that he is not
liable for the accuracy-related penalty under section 6662
because he reasonably relied on the advice of tax professionals.
We disagree. Petitioner did not name any professionals or say
what information he provided to them. We conclude that
petitioner did not rely on the advice of tax professionals, and
that he is liable for the accuracy-related penalty under section
6662(a) for 1996.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011