Elaine Hang - Page 6

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         return or any of the attached schedules.  Petitioner contends                
         that she is not liable for the penalty, because she relied on her            
         C.P.A. to prepare her tax return and to ensure tax compliance.               
         Petitioner relies solely on her oral testimony and has not shown,            
         by a preponderance of the evidence, that her C.P.A. possessed                
         sufficient relevant information or expertise to warrant her                  
         reliance on the C.P.A.’s judgment.                                           
              Respondent’s determination that petitioner is liable for an             
         accuracy-related penalty under section 6662(a) is accordingly                
         sustained.                                                                   
              Reviewed and adopted as the report of the Small Tax Case                
         Division.                                                                    

                                                 Decision will be entered             
                                            for respondent.                           





















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