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contacting J.E. & Assoc. to obtain his records and any
substantiating documentation for 1995, he was told that J.E. &
Assoc. did not handle petitioner’s account in 1995, although the
signature of the tax preparer for petitioners’ 1995 tax return was
that of a representative of J.E. & Assoc. Further attempts by
petitioner to reach J.E. & Assoc. proved unsuccessful. In
addition, petitioner testified at trial that his counsel, who
withdrew 2 months before trial, handled most matters for
petitioner.
Although petitioner failed to present either the accountants
or his former counsel as witnesses to show that his reliance was
reasonable, we found petitioner’s testimony in this regard to be
credible. Petitioner, through his testimony, demonstrated that he
simply had no available documentation to offer to substantiate the
claimed expenses.
Petitioner provided all his records to Accufast and believed
that the deductions claimed by Accufast as reflected on the 1993
and 1994 tax returns were accurate. It is clear from the record
that petitioner is an unsophisticated taxpayer with a limited
education who relied reasonably and in good faith on Accufast.
Consequently, we conclude that for 1993 and 1994, petitioner
had reasonable cause and acted in good faith as to any underpayment
resulting from the deductions in issue. Accordingly, we hold that
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