Caspian Consulting Group, Inc. - Page 4

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               It is clear from the record that petitioner provided Cameron           
          & Rolling all records and information necessary to prepare the              
          2000 Federal income tax return and claim the deductions set forth           
          on the return.  A Cameron & Rolling accountant conversed with               
          petitioner’s owners to determine that the depreciation and                  
          expenses related to the airplane could be deducted.  Petitioner             
          relied upon Cameron & Rolling to prepare the return, and Cameron            
          & Rolling was aware of petitioner’s reliance.  It is clear from             
          the record that petitioner reasonably relied in good faith on               
          Cameron & Rolling.  Consequently, we conclude that for the year             
          in issue petitioner had reasonable cause and acted in good faith            
          as to any underpayment resulting from the deductions in issue.              
          Accordingly, we hold that petitioner is not liable for the                  
          penalty pursuant to section 6662(a).                                        
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for petitioner as to the 2000            
                                             penalty and for respondent as            
                                             to the deficiencies.                     













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