Frederic W. Thrane, Jr. - Page 9

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          1998).  In appropriate circumstances, nonetheless, a taxpayer's             
          reliance on his accountant's preparation of the return, including           
          the computations thereon, may constitute reasonable cause.  See             
          Harrison v. Commissioner, supra; Drummond v. Commissioner, supra.           
               In order for a taxpayer's reliance on professional advice to           
          constitute reasonable cause to negate a section 6662(a) accuracy-           
          related penalty, the taxpayer must show that (1) the adviser was            
          a competent professional who had sufficient expertise to justify            
          reliance, (2) the taxpayer provided necessary and accurate                  
          information to the adviser, and (3) the taxpayer actually relied            
          in good faith on the adviser's judgment.  Neonatology Associates,           
          P.A. v. Commissioner, supra at 98; see also Charlotte's Office              
          Boutique, Inc. v. Commissioner, 425 F.3d 1203, 1212 & n.8 (9th              
          Cir. 2005), affg. 121 T.C. 89 (2003); Cramer v. Commissioner, 101           
          T.C. 225, 251 (1993), affd. 64 F.3d 1406 (9th Cir. 1995).                   
               On the basis of our review of all the facts and                        
          circumstances, we conclude that petitioner had reasonable cause             
          with respect to the substantial understatement in this case.                
          Except for the single error arising from the inadvertent double-            
          deducting of Windsor's officer compensation, OSG competently                
          prepared Windsor's and petitioner's returns for 2001; there is no           
          evidence of other defects in either, for the year in issue or               
          prior years.  Thus, petitioner's reliance on OSG's competence was           
          reasonably justified.  Windsor, which petitioner controlled,                






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