- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011