- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011