- 17 -
Petitioner was not required to second guess attorney Konvalinka’s
advice. See United States v. Boyle, supra at 251 (“To require
the taxpayer to challenge the attorney, to seek a ‘second
opinion,’ or to try to monitor counsel on the provisions of the
Code himself would nullify the very purpose of seeking the advice
of a presumed expert in the first place.”). Petitioner has
therefore demonstrated reasonable cause and good faith for the
underpayment. As a result, she is not liable for an accuracy-
related penalty under section 6662.
The Court has considered all of petitioner’s and
respondent’s contentions, arguments, requests, and statements.
To the extent not discussed herein, we conclude that they are
meritless, moot, or irrelevant.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008