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reliance on the advice of a professional such as an accountant.
See id. Further, an honest misunderstanding of fact or law that
is reasonable in light of the experience, knowledge, and
education of the taxpayer may indicate reasonable cause and good
faith. See Remy v. Commissioner, T.C. Memo. 1997-72.
At the time the return was prepared, Mr. Hertz was an
enrolled agent. Petitioners had engaged Mr. Hertz to prepare
their income tax returns for 1 or 2 years before 1999.
a. Deductions Relating to Mr. Davis’s Photography
Activities
Petitioners honestly misunderstood Mr. Davis’s photography
expenditures to be deductible business expenses. Although
petitioners are both highly educated in fields that do not relate
to taxation, we find that their misunderstanding was reasonable.
We therefore conclude that petitioners had reasonable cause and
acted in good faith as to the underpayments resulting from
deductions of photography-related expenditures.
b. Gross Receipts and Deductions of Dr. Rinker’s
Medical Practice
Petitioners credibly testified that they provided Mr. Hertz
with all of the necessary records and information with which to
determine the gross receipts and allowable deductions for Dr.
Rinker’s medical practice, and that they relied on Mr. Hertz to
determine the proper figures on their return. We conclude that
for 1999 petitioners had reasonable cause and acted in good faith
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