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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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