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accountant does not necessarily make him a competent tax adviser.
While petitioner at trial focused his examination of Jung’s
qualifications on establishing that he is in fact a certified
public accountant, petitioner made a feeble attempt to ferret out
the professional qualifications of Jung as to tax matters. We do
know from Jung’s testimony, however, that he admittedly has an
incomplete understanding of section 274 and its application to
this case.
Second, the record establishes that petitioner did not give
Jung all of the available information that he needed to report
the disputed deductions correctly and that Roach actually gave
Jung misinformation on the Centurion that affected his reporting
of those deductions. As to the latter, Jung testified, his
understanding of section 274(a)(1)(B) was that it applied only to
boats that were out for long periods of time or that had people
sleeping on board and that it did not apply to stationary boats
which were simply used as a conference room or meeting place,
such as he believed was the case as to petitioner’s use of the
Centurion.
Third, the record establishes that Roach, as an officer of
petitioner, did not in good faith rely upon his stated belief
that Jung would prepare the subject returns correctly. Roach, a
lawyer, obviously knew that Jung would have needed, but did not
have, all relevant available information on the Centurion in
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