- 21 - judgment. Neonatology Associates, P.A. v. Commissioner, supra at 98-99. Petitioner asserts a reliance defense as the basis for relief from liability under section 6662(a). Petitioner hired Mr. Isaacson, an attorney with an LL.M. in taxation who specializes in Federal tax law, and provided him with all the necessary and accurate information with respect to all items reported on his returns. Using the information provided, Mr. Isaacson prepared a tax opinion letter which represented to petitioner there was a reasonable legal basis to fully deduct and carry back AMT losses for the years at issue. Relying in good faith upon this advice, petitioner hired Mr. Isaacson to prepare his 2000 amended return, which respondent accepted; subsequent 2000 amended returns; 2001 return; and subsequent 2001 amended return. The deficiencies at issue were determined from the positions reported in the returns Mr. Isaacson prepared on behalf of petitioner. Petitioner is unsophisticated in Federal tax law. For the foregoing reasons, the Court concludes petitioner reasonably and in good faith relied on the advice of a competent professional and holds petitioner is not liable for the section 6662(a) penalties.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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