Connie J. Meadows - Page 15

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        Petitioner testified that she relied on her accountant, who                   
        is a certified public accountant.  Petitioner further testified               
        that she provided her accountant with the necessary information               
        for him to prepare returns and that she believed her accountant               
        had requested extensions of the time to file.  We are not                     
        satisfied that petitioner’s actions amounted to a good faith                  
        effort to comply with income tax laws.  Even giving petitioner the            
        benefit of the doubt that she relied on, or more likely                       
        misunderstood, her accountant’s advice, petitioner was certainly              
        aware of the obligation to file income tax returns, which she did             
        for 2000, the tax year for which she believed she was entitled to             
        a refund.  Her understanding (or, more likely, misunderstanding)              
        of her accountant’s advice with respect to later years amounts to             
        an endorsement of a strategy of preventing the Government from                
        applying the refund she expected with respect to the 2000 tax year            
        to a tax that she might owe in later years.  This does not                    
        constitute a good faith effort to comply with income tax laws.                
        Consequently, this factor weighs against petitioner.                          
             Not all the factors in section 4.03 of the modified                      
        guidelines weigh against petitioner, just as not all of the                   
        factors in section 4.01 or 4.02 of the modified guidelines weigh              
        against her.  However, because we find that:  Respondent is                   

             4(...continued)                                                          
          2001; petitioner was therefore not entitled to this tax credit              
          for years after 2000.                                                       




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