(case involves IRS attempt to issue penalties with respect off-shore irrevocable, asset-protection trust that plaintiff established in West Indies; plaintiff reported trust to IRS on Form 3520-A, but did not file Form 3520 which potentially subjected plaintiff to penalty under I.R.C. Sec. 6677(a) of greater of $10,000 or 35% of gross reportable amount (which would exceed $578,000); exception for penalty exists if failure to file due to reasonable cause and not due to willful neglect; plaintiff claimed reasonable reliance on accountant and that plaintiff lacked personal knowledge of Form 3520 filing requirements; IRS moved for summary judgment that exception to penalty did not apply; court denied motion on basis that plaintiff provided accountant with all applicable trust documents, relied on accountant to advise him on trust filings, accountant did advise plaintiff on some tax matters relating to trust, accountant prepared plaintiff's personal returns and plaintiff believed all returns had been filed; no mention of whether plaintiff failed to report trust income).