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employed a part-time bookkeeper/accountant to serve as a contact
with OSG, and OSG prepared Windsor's audited financial
statements. We are consequently satisfied that OSG had full
access to all necessary information and that the understatement
on petitioner's return is not attributable to petitioner's
failure to provide accurate information.
We also conclude that petitioner actually and reasonably
relied in good faith on OSG's professional expertise. Respondent
argues otherwise, relying on Metra Chem Corp. v. Commissioner,
supra. Respondent seeks to draw a parallel between the instant
case and Metra Chem, where two taxpayer-shareholders of a C
corporation failed to report $10,000 and $6,800, respectively, in
cash dividends paid to them by the corporation, amounts which
were large in relation to the taxpayers' other income (over 20
percent thereof). The taxpayers argued that they had reasonable
cause for the omissions because they relied on their accountant
to prepare their returns. The accountant had also prepared the
corporate return and had access to the corporate books showing
the dividends. We declined to find reasonable cause, for two
reasons. First, reliance on professional advice constitutes
reasonable cause only where complex transactions are involved,
and reporting the receipt of cash dividends was not a complex
transaction, we reasoned. Second, we noted that a review of the
taxpayers' returns would have revealed the erroneous omissions.
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