- 77 - deductions, and return reporting and that they appropriately followed the advice and return reporting positions of those professionals. Respondent, however, sees petitioners as sophisticated and successful business people who understand complex legal concepts in connection their Beneco business. Respondent contends that petitioners should have known that the positions they took on their returns were incorrect. Respondent also points out that petitioners have conceded their offshore leasing issue and the penalties determined with respect to it and that those transactions reflected that petitioners had a high tolerance for risk in their tax reporting. In essence, respondent argues that petitioners were willing to take aggressive tax reporting positions and that we should consider that in evaluating petitioners’ other deductions and reporting positions. Petitioners claim to have relied upon their accountants for the contribution and section 183 loss issues. Mr. Kramer prepared petitioners’ returns for the years 1998 through 2001. Petitioners each testified that they relied upon Mr. Kramer to properly prepare their returns. Petitioners’ Accuracy-Related Penalties for Their Noncash Charitable Contribution Adjustments for the 1998, 1999, 2000, and 2001 Tax Years Each couple conceded that they are liable for the accuracy- related penalties with respect to their offshore leasing transactions, a matter which affected their liabilities forPage: Previous 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 NextLast modified: March 27, 2008