- 19 - lacking substance); Mitchell v. Commissioner, T.C. Memo. 2001-269 (lawyer-accountant held liable for accuracy-related penalty for deducting farm losses with no credible plan to make profit); Emerson v. Commissioner, T.C. Memo. 2001-186 (lawyer liable for accuracy-related penalty for failing to keep adequate records required by section 6001). Petitioner has been a tax return preparer since at least 1990. Between 1993 and 1995, he prepared at least 500 tax returns and was paid for his services. Given petitioner's experience in preparing tax returns and his knowledge that petitioners were previously held liable for omitting income and failing to substantiate expenses, this Court concludes that he failed to act with reasonable cause and in good faith in determining his tax liability. See Wilkerson v. Commissioner, T.C. Memo. 1998-68 (C.P.A. and wife, experienced return preparers who failed to report fees and other income, were held liable for negligence penalty). The Court holds that petitioners are liable for the accuracy-related penalties under section 6662(a). Reviewed and adopted as the report of the Small Tax Case Division.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011