- 9 - Pritchett v. Commissioner, 63 T.C. 149, 175-176 (1974). The record reflects that Mr. Kington, the preparer of her original Federal income tax returns, was petitioner’s accountant for 7 years. However, petitioner has not shown Mr. Kington’s qualifications or what records she provided to him in order to prepare her returns.5 Therefore, we are unable to find that petitioner’s reliance on Mr. Kington was in fact reasonable. The record also reflects that petitioner relied on Mr. Nemiroff, her attorney, in submitting amended returns for 1994 and 1995.6 However, in the context of this case, petitioner’s reliance on her attorney and her willingness to correct her mistakes are irrelevant. As respondent has applied the section 6662(a) penalty to the underpayment reflected on petitioner’s original returns, we measure petitioner’s good faith and reasonable reliance as of the date of filing her original returns. In that regard, petitioner argues that the penalty should apply to the underpayment reflected on petitioner’s amended, as 5 The credentials of Ron Kington are unclear from the record. 6 Petitioner also contends that, on the advice of her attorney, she hired a new accountant to prepare her amended returns. Other than petitioner’s testimony, there is no evidence that she did so. In that regard, petitioner’s amended returns are not even signed by a tax preparer.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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