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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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Last modified: May 25, 2011