Walter Joseph Hess - Page 5

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          did not receive $5,619 of rental income.  As a result, the amount           
          of tax required to be shown on the return must be based on the              
          amount determined pursuant to the Rule 155 computations.  If the            
          amount determined pursuant to such computations meets the                   
          requirements of section 6662(d)(1), petitioner will be liable for           
          the substantial understatement penalty.  See Carlson v.                     
          Commissioner, 116 T.C. 87, 109-110 (2001).                                  
               Petitioner contends that he should be excused from the                 
          section 6662(a) penalty because he relied on his accountant to              
          determine his tax liability.  Section 6664(c)(1) provides that no           
          section 6662(a) penalty shall be imposed if there was reasonable            
          cause for the underpayment and the taxpayer acted in good faith.            
          Reliance on the advice of an accountant does not constitute                 
          reasonable cause and good faith if the taxpayer fails to review             
          the return before filing it.  Metra Chem Corp. v. Commissioner,             
          88 T.C. 654, 662 (1987).  Petitioner did not review his return              
          prior to filing it.  Thus, the section 6662(a) penalty is                   
          sustained if, after the Rule 155 computations, petitioner’s                 
          understatement meets the requirements of section 6662(d)(1).                
               Contentions we have not addressed are irrelevant, moot, or             

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