Frederic W. Thrane, Jr. - Page 7

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          Accordingly, respondent has satisfied his burden of production              
          and petitioner bears the burden of establishing the applicability           
          of the reasonable cause exception.                                          
               A penalty under section 6662(a) will not be imposed with               
          respect to any portion of the underpayment as to which the                  
          taxpayer acted with reasonable cause and in good faith.  Sec.               
          6664(c)(1).  The determination as to whether a taxpayer acted               
          with reasonable cause and in good faith is made on a case-by-case           
          basis, taking into account all the pertinent facts and                      
          circumstances.  Sec. 1.6664-4(b)(1) and (c), Income Tax Regs.               
          "An isolated computational or transcriptional error generally is            
          not inconsistent with reasonable cause and good faith."  Sec.               
          1.6664-4(b)(1), Income Tax Regs.  Further,                                  
               Reliance * * * on the advice of a professional tax                     
               advisor * * * does not necessarily demonstrate                         
               reasonable cause and good faith.  * * *  Reliance on                   
               * * * professional advice, or other facts, however,                    
               constitutes reasonable cause and good faith if, under                  
               all the circumstances, such reliance was reasonable and                
               the taxpayer acted in good faith. * * *  [Id.]                         
               In United States v. Boyle, 469 U.S. 241, 251-252 (1985), the           
          Supreme Court held that, because it requires no tax expertise to            
          ascertain a deadline and meet it, a taxpayer's reliance on a tax            
          professional to make a timely filing of a return does not                   
          constitute reasonable cause for a late filing of a return.  In so           
          holding, the Supreme Court also stated a corollary:  "When an               
          accountant or attorney advises a taxpayer on a matter of tax law,           






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