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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
meritless.
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