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properly reported all income and expenses, and she relied on the
advice of a tax professional.
We conclude that petitioner did not act with reasonable
cause or good faith. We conclude that her reliance on the advice
of a tax professional is not reasonable or in good faith.
Accordingly, petitioner is liable for the accuracy-related
penalty.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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