Elizabeth Giles - Page 49

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          expenses for the years in issue.  Mr. Wessman’s testimony                   
          that petitioner provided him with all the necessary                         
          information is bolstered by respondent’s concession.  Mr.                   
          Wessman further testified that he believed petitioner’s                     
          returns were correct as filed.  Petitioner credibly                         
          testified that she relied on Mr. Wessman in determining the                 
          tax treatment of her horse activity.                                        
               Petitioner did not produce any books, records, or other                
          work papers in response to respondent’s initial contact                     
          letter.  Additionally, petitioner did not agree to extend                   
          the period of limitations or participate in the appeal                      
          process.  However, Mr. Wessman credibly testified that such                 
          actions were taken in order to expedite the review process                  
          so that the years in issue could  be consolidated with the                  
          prior Tax Court case.  Given the circumstances, we find                     
          petitioner did not act in bad faith.                                        
               We conclude that petitioner acted with reasonable cause                
          and in good faith.  Accordingly, we hold that petitioner is                 
          not liable for the accuracy-related penalties under section                 
          6662(a).                                                                    
               In reaching our holdings, we have considered all                       
          arguments and contentions made, and, to the extent not                      
          mentioned, we conclude that they are moot, irrelevant, or                   
          without merit.                                                              






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