Kevin L. and Victoria L. Hargrove, et al. - Page 17

                                        -17-                                          
          justify reliance or that Mr. and Mrs. Breeding provided the                 
          preparer all relevant information.  See Neonatology Associates,             
          P.A. v. Commissioner, supra.  We therefore do not find that Mr.             
          and Mrs. Breeding have shown that it was reasonable to rely on              
          this tax return preparer.                                                   
               After considering all of the facts and circumstances, we               
          find that Mr. and Mrs. Hargrove and Mr. and Mrs. Breeding have              
          failed to establish that they had reasonable cause and acted in             
          good faith with respect to their respective underpayments.                  
          Accordingly, we sustain respondent’s determination as to Mr. and            
          Mrs. Hargrove and Mr. and Mrs. Breeding for the accuracy-related            
          penalties for the relevant years.                                           
               We have considered all remaining arguments the parties made            
          and, to the extent not addressed, we conclude they are                      
          irrelevant, moot, or meritless.                                             
               To reflect the foregoing and the concessions of the parties,           

                                                  Decisions will be entered           
                                             for respondent in Docket Nos.            
                                             16441-04, 16442-04, 16444-04,            
                                             and 16448-04.  Decision will             
                                             be entered for respondent in             
                                             Docket No. 16443-04 with                 
                                             respect to the deficiencies              
                                             and for petitioners with                 
                                             respect to the section 6662(a)           
                                             penalties.                               




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