- 9 - construction business remained consistent. Petitioners offered no explanation for the reduced income tax reported on the returns other than the change in return preparer. We cannot excuse a taxpayer who makes little or no effort to discern whether the person the taxpayer has chosen to prepare a return is competent to give tax advice. We find that petitioners did not act in good faith in relying on Mr. Borrelli’s advice. Accordingly, we find that petitioners did not have reasonable cause for, nor did they act in good faith with respect to, the understatements of income tax. We therefore sustain respondent’s determination that petitioners are liable for the section 6662(a) penalty for each of the years at issue. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011