- 18 - Petitioners’ accountant had been preparing their returns for approximately 19 years including preparing the return at issue. When petitioners signed the closing agreement in 1998, they provided a copy to their accountant. A review of petitioners’ 2000 return reveals that petitioners submitted to their accountant all the information necessary for their accountant to provide tax advice and prepare the return. In particular, petitioners sought advice from their accountant whether they were entitled to any exclusions. Unsure as to their entitlement, petitioners paid their accountant to research these specific issues. After such research, petitioners’ accountant concluded that they were so entitled and prepared the returns excluding income under sections 119 and 912 from petitioners’ gross income. Therefore, we find that petitioners reasonably and in good faith relied on the advice of their accountant. Accordingly, we hold that petitioners were not negligent in relying on their accountant and thus are not liable for the accuracy-related penalty under section 6662(a). Conclusion We have considered all of the other arguments made by the parties, and, to the extent that we have not specifically addressed them, we conclude that they are without merit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011