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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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Last modified: May 25, 2011