- 5 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011