- 11 - facts and circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs. Relevant factors include the taxpayer's efforts to assess his proper tax liability, including the taxpayer's reasonable and good-faith reliance on a tax professional, such as an accountant. Id. On the facts and testimony before us and in light of the tax adjustments involved herein, we believe that petitioners reasonably relied on the advice of their C.P.A. in the preparation of the tax returns in issue. Petitioners had reasonable cause for the deficiencies in issue, and petitioners acted in good faith. Petitioners are not liable for the accuracy-related penalties determined by respondent under section 6662 with respect to the deficiencies in issue herein. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011