- 12 -
payable to petitioner into his trust account and paid petitioner
the net settlement proceeds with a check drawn on that account.
Thus, we find that petitioner’s attorney had complete knowledge
of all the necessary and relevant facts of petitioner’s lawsuit
and the settlement agreement. Moreover, there is nothing in the
record to show that petitioner had any reason to suspect her
attorney’s advice was not competent. Considering all the facts
and circumstances in this case, we find that petitioner acted
with reasonable cause and in good faith with respect to the
underpayment for the year at issue. See sec. 6664(c)(1).
Accordingly, we conclude that petitioner is not liable for the
accuracy-related penalty imposed under section 6662(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011