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relevant facts and circumstances, and most importantly, the
extent to which he attempted to assess his proper tax liability.
See Neely v. Commissioner, 85 T.C. 934 (1985); Stubblefield v.
Commissioner, T.C. Memo. 1996-537; sec. 1.6664-4(b)(1), Income
Tax Regs. As petitioner has not shown this Court the method by
which she kept track of her business profits and losses, we are
unable to find that petitioner attempted, in good faith, to
properly assess her tax liability.
Despite this, petitioner maintains that there are other
factors which show she acted in good faith. Petitioner points
out that (1) she relied upon an accountant who prepared her
original Federal income tax returns; (2) she submitted bank
statements to respondent’s examiner upon notice of audit; (3) she
corrected the discrepancies on her returns; (4) she paid the tax
due; and (5) she hired and relied on tax professionals.
Reliance on the advice of a competent adviser can be a
defense to the accuracy-related penalty. United States v. Boyle,
469 U.S. 241, 252 (1985); Zfass v. Commissioner, 118 F.3d 184
(4th Cir. 1997), affg. T.C. Memo. 1996-167; sec. 1.6664-4(b)(1),
Income Tax Regs. However, it must be established that the
reliance was reasonable, in good faith, and based upon full
disclosure. Ewing v. Commissioner, 91 T.C. 396, 423-424 (1988),
affd. without published opinion 940 F.2d 1534 (9th Cir. 1991);
Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662 (1987);
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