Mediaworks, Inc. - Page 20

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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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