If I understand your facts, you'd not meet this test, because the professional knew the facts but not the law in the area. Am I understanding that right? My quote is from this article, which is worth your reading. http://www.paleyrothman.com/wp-content/ ... gy-03_.pdfIn Neonatology
Associates, P.A., 115 TC 43 (2000), a f f d 299 F.3d 221 (CA-3,2002), fhe Tax Court indicated that to qualify for relief based on reliance on a tax advisor, the taxpay- er must show that (1) fhe advisor was a competent professional; (2) the advisor was provided with all necessary infor- mation; and (3) the taxpayer reasonably relied on the advisor in good faith.
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