Nariman Teymourian - Page 20

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          amounts of income not reported but eventually conceded by                   
          petitioner, the characterization of those amounts was open to               
          reasonable doubt at the time petitioner filed his returns. Based            
          upon Mr. Rolling’s testimony and on other evidence submitted, we            
          find that Mr. Rolling was provided with necessary and accurate              
          information by both petitioner and Caspian.  Finally, based upon            
          petitioner’s credible testimony, we find that petitioner relied             
          on Mr. Rolling for the preparation of his tax returns during the            
          years in issue, and that petitioner’s reliance was in good faith.           
               For the foregoing reasons, we conclude that petitioner                 
          reasonably and in good faith relied on the advice of a competent            
          professional, and we hold that petitioner is not liable for the             
          section 6662(a) penalties.                                                  
               We hold that petitioner did not receive rental income during           
          the years in issue and is thus not liable for any income tax                
          deficiencies relating to rental income.  We further hold that               
          disbursements made by Caspian to and on behalf of petitioner were           
          loans and not constructive dividends.  Finally, we hold that                
          petitioner is not liable for accuracy-related penalties.                    
               In reaching our holdings, we have considered all arguments             
          made, and, to the extent not mentioned, we conclude that they are           
          moot, irrelevant, or without merit.                                         

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