- 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