- 43 -
Because petitioners failed to prove they reasonably relied
on a fully informed and competent tax adviser and because they
did not assert any other basis for relief from the section
6662(a) penalty, we hold that petitioners have failed to prove
that they had reasonable cause within the meaning of section
6664(c). We, therefore, sustain respondent’s determination that
petitioners are liable for the accuracy-related penalty under
section 6662(a).
Because the OMK trusts are disregarded for Federal income
tax purposes, there are no deficiencies in their Federal income
taxes. To reflect the foregoing,
Decision will be entered under
Rule 155 in docket No. 20060-02.
Decisions will be entered for
petitioners in docket Nos. 20202-02
and 20203-02.
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