J. Ramsay Farah and Elizabeth Farah - Page 29

               Petitioners argue that they sought professional tax advice             
          for the preparation and filing of their 2001 return.  Petitioners           
          presented no evidence of the competence or expertise of their               
          return preparers.  Therefore, petitioners have failed to meet the           
          first prong of the Neonatology test.  See G. Kierstead Family               
          Holdings Trust v. Commissioner, T.C. Memo. 2007-158.                        
               Petitioners further argue that they provided their return              
          preparers with all their raw financial data.  Petitioners’ 2001             
          return listed the amount realized on the sale of their residence            
          as $600,000 and the adjusted basis as $600,000.  Neither of these           
          numbers is accurate.  The gross proceeds were $800,000, the net             
          proceeds were $752,582, and the adjusted basis was either                   
          $597,054 or $647,054.  Furthermore, the return did not report any           
          amount with respect to the $500,000 of gross proceeds received              
          from the sale of the South Point Road lot.  Considering these               
          major errors and omissions, either petitioners failed to provide            
          their preparers with the necessary information, or the preparers            
          lacked the expertise to properly file a Federal income tax                  
               Because petitioners failed to prove they reasonably relied             
          on a competent tax professional, and because they failed to                 
          assert any other basis for relief, we hold that petitioners                 
          are liable for an accuracy-related penalty under section 6662(a).           
               In reaching our holdings, we have considered all arguments             

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