Nariman Teymourian - Page 19

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          do not need to reach the issues of whether the resulting                    
          underpayments were substantial or were due to negligence because            
          we find petitioner had reasonable cause and acted in good faith.            
               A taxpayer’s reliance on the advice of a professional as to            
          the tax treatment of certain items does not automatically                   
          constitute reasonable cause.  Neonatology Associates v.                     
          Commissioner, 115 T.C. 43, 98-99 (2000), affd. 299 F.2d 221 (3d             
          Cir. 2002); see sec. 1.6664-4(c)(1), Income Tax Regs.  For a                
          taxpayer to reasonably rely on the advice of a professional, the            
          taxpayer must show: (1) The adviser was a competent professional            
          who had sufficient expertise to justify reliance; (2) the                   
          taxpayer provided necessary and accurate information to the                 
          adviser; and (3) the taxpayer actually relied in good faith on              
          the adviser’s judgment.  Neonatology Associates v. Commissioner,            
          supra at 98-99.                                                             
               Mr. Rolling has a B.A. in business administration and a                
          master’s degree in taxation.  He is a licensed C.P.A. and has               
          been practicing for more than 20 years.  During the years in                
          issue, Mr. Rolling prepared tax returns for petitioner and                  
          Caspian, and served as a general consultant to both on tax-                 
          related issues.  Throughout the course of Mr. Rolling’s                     
          testimony, we found him to be a competent professional who had              
          sufficient expertise to justify petitioner’s reliance.  Based               
          upon the testimony of petitioner and Mr. Rolling regarding the              

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