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prepare its Federal income tax returns correctly. We disagree
with petitioner’s assertion that it relied reasonably upon Jung
to prepare its tax returns correctly. While it is true that the
reliance on the advice of a professional as to the tax treatment
of an item may sometimes be enough to escape the imposition of a
section 6662(a) accuracy-related penalty, see United States v.
Boyle, 469 U.S. 241 (1985); sec. 1.6664-4(b), Income Tax Regs.,
the mere fact that a taxpayer such as petitioner claims to have
relied upon a professional is not enough to fall within this
defense. A taxpayer such as petitioner seeking to avail itself
of this defense must prove by a preponderance of evidence:
(1) The professional was a competent tax adviser who had
sufficient expertise to justify reliance; (2) the taxpayer
provided necessary and accurate information to the adviser; and
(3) the taxpayer actually relied in good faith on the adviser’s
judgment. Neonatology Associates, P.A. v. Commissioner, 115 T.C.
43, 99 (2000), affd. 299 F.3d 221 (3d Cir. 2002); see also
Catalano v. Commissioner, 240 F.3d at 845 (the reasonable
reliance defense requires that the taxpayer establish the
professional qualifications of a purported expert and the nature
of the advice that was purportedly given).
On the basis of the credible evidence in the record, we are
unable to conclude that any of these three requirements has been
met. First, the mere fact that Jung is a certified public
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