- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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