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Apart from passing references to the tax return preparer in
petitioner’s testimony, the record is devoid of evidence to
support petitioners’ claim that the position taken on their 2000
return was consistent with the tax return preparer’s advice.
Petitioners did not call their tax return preparer as a witness.
There is no evidence establishing the qualifications of
petitioners’ tax return preparer or that petitioners provided
their tax return preparer with all relevant information.
Respondent’s imposition of the section 6662(a) accuracy-
related penalty is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011