Frederic W. Thrane, Jr. - Page 12

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          accountants in Harrison v. Commissioner, supra, who computed the            
          taxpayers' estimated tax liability for extension purposes as                
          $1,408 and $2,200 for 1988 and 1989, respectively, when the                 
          amount ultimately reported as due on the return was $96,418                 
          (ultimately stipulated as $175,686) and $38,702 (ultimately                 
          stipulated as $116,389), respectively.  Notwithstanding these               
          discrepancies, we concluded that the taxpayers in Harrison had              
          reasonable cause for late filing as a result of their reliance on           
          their accountants to perform the calculations of estimated tax              
          necessary to obtain extensions.                                             
               Finally, as noted above, the regulations provide that an               
          isolated computational error generally is not inconsistent with             
          reasonable cause and good faith.  The error underlying                      
          petitioner's income omission of $173,093, wherein his accountants           
          failed to remove that amount from salaries generally when they              
          separately stated it as officer compensation in the                         
          electronically stored version of petitioner's S corporation's               
          Form 1120S, resembles the kind of isolated computational error              
          generally intended to give rise to relief.                                  
               We accordingly hold that petitioner had reasonable cause for           
          the understatement attributable to his failure to report $173,093           
          of income from Windsor in 2001.                                             









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