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A taxpayer reasonably relied on a professional tax adviser
if the adviser was a competent professional who had sufficient
expertise to justify the taxpayer’s reliance on him or her, the
taxpayer provided necessary and accurate information to the
adviser, and the taxpayer relied in good faith on the adviser’s
judgment. See Neonatology Associates, P.A. v. Commissioner, 115
T.C. 43, 99 (2000), affd. 299 F.3d 221 (3d Cir. 2002). A
taxpayer generally must prove each of these elements to show his
or her reliance on a professional tax adviser was reasonable.
Bowen v. Commissioner, T.C. Memo. 2001-47.
Petitioner argues that she reasonably relied on the advice
of a professional tax adviser, Mr. Wood. We disagree.
Petitioner proved that Mr. Wood is a competent professional who
had sufficient expertise to justify her reliance on him.
Petitioner did not show, however, that she provided all the
necessary and accurate information to Mr. Wood for him to
consider her situation and render tax advice. Moreover,
petitioner did not show that she relied in good faith on Mr.
Wood’s tax advice because she did not establish what tax advice,
if any, Mr. Wood rendered. We therefore do not find that
petitioner reasonably relied on a professional tax adviser.
After considering all the facts and circumstances, we find
that petitioner has failed to establish that she had reasonable
cause and acted in good faith with respect to the underpayment of
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