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proper tax liability, including the taxpayer's reasonable and
good faith reliance on the advice of a tax professional. See
id.; see also sec. 1.6664-4(c), Income Tax Regs. Further, an
honest misunderstanding of fact or law that is reasonable in
light of the experience, knowledge, and education of the taxpayer
may indicate reasonable cause and good faith. See Remy v.
Commissioner, T.C. Memo. 1997-72.
Petitioners assert that they had reasonable cause for the
various positions taken on all their returns. In considering
this issue, we note that Mr. Doxtator was a well-informed
taxpayer. He was a volunteer tax return preparer for the IRS
between 1996 and 1998. In these proceedings, he has cited
taxation and Indian law authorities extensively. Moreover, in
their previous case before this Court, petitioners claimed an
exemption from tax, based on their status as Native Americans,
for tier II railroad retirement benefits, but they failed to
identify any treaty or statute providing such an exemption. Our
opinion to that effect was issued before any of the return
positions at issue herein were taken. In this context, we
address petitioners' return positions.
We find no reasonable cause for petitioners' position that
Mrs. Doxtator's judicial officer compensation is not subject to
income tax in 1997 and 1999. Petitioners disregarded information
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