Francis N. and Patricia A. Leonard - Page 14

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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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