- 8 -
(2000), affd. 299 F.3d 221 (3d Cir. 2002); Ellwest Stereo
Theatres v. Commissioner, supra.
Petitioner contends that he relied on the tax return
preparer to prepare his tax return and to ensure tax compliance
since he has no knowledge of tax laws. Petitioner has not
presented any evidence that he had provided necessary and
accurate information to the preparer or that the preparer
possessed sufficient relevant information or expertise to warrant
petitioners’ reliance on the preparer’s judgment.
Respondent’s determination that petitioners are liable for
accuracy-related penalties under section 6662(a) is accordingly
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011