Viola v. Comr., T.C. Memo. 2013-213

(petitioner’s tax preparer failed to report almost $800,000 of income on petitioner’s Schedule C; amount not reported to petitioner or IRS on Form 1099-Misc.; tax preparer suffered stroke and firm prepared return close to filing deadline; petitioner received copy of return three weeks after filed (after filing deadline) and noticed missing income, but assumed it was reported somewhere else on return; IRS asserted accuracy-related penalty, but petitioner argued that reasonable cause and good faith reliance on professional advice present; court agreed with IRS; petitioner should have confirmed that income actually reported elsewhere on return rather than simply assuming it was).