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the meaning of section 6662(b)(1) and section 1.6662-3(b)(1),
Income Tax Regs. See Sherman v. Commissioner, T.C. Memo. 1989-
269. Moreover, even if those return positions are considered
negligent, we find that petitioner qualifies for the reasonable
cause exception provided by section 6664(c)(1).
Both the originally filed 1999 return and the 1999 amended
return were prepared by Ronald O’Donnell, and petitioner relied
on Mr. O’Donnell to defend those returns on audit. Petitioner
did not introduce evidence that Mr. O’Donnell qualifies as a tax
expert although Mr. O’Donnell’s testimony indicates that he has
had experience in preparing tax returns and defending them on
audit. Conversely, respondent failed to discredit Mr. O’Donnell
as a tax expert. Although the evidence bearing upon Mr.
O’Donnell’s tax expertise is slight, we conclude that a
preponderance of that evidence favors petitioner. Therefore, we
find that Mr. O’Donnell was, at the very least, a knowledgeable
tax return preparer, and that petitioner acted reasonably in
relying upon his approval of the Schedule A deduction for
unreimbursed employee business expenses, the substantiated
Schedule C deductions, and head of household filing status for
petitioner. See Ballard v. Commissioner, T.C. Memo. 1996-68. It
is stipulated, however, that petitioner failed to substantiate to
any degree either the $617 Schedule A deduction for tax
preparation fees or $1,422 of office expense and $1,336 of
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