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Orloff was experienced in tax matters and held himself out as a
tax practitioner. Petitioner reasonably relied on his advice,
and we find that he is not liable for the penalty under section
6662(a). Woody v. Commissioner, 19 T.C. 350, 355 (1952).
Contentions we have not addressed are irrelevant, moot, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011