A taxpayer gave her CPA all relevant information, the CPA was competent, and she relied in good faith on his advice about a deduction later disallowed. The 20% accuracy-related penalty:
No accuracy-related penalty applies to any portion of an underpayment if the taxpayer shows reasonable cause and good faith under section 6664(c). Reasonable reliance on professional advice qualifies when the adviser was competent, the taxpayer gave complete and accurate information, and the taxpayer actually relied on the advice in good faith. Source: IRC 6664(c)(1); Treas. Reg. 1.6664-4(b)-(c). Tax year: 2025 (law as of 31 Dec 2025).
Thinking only Form 8275 disclosure avoids the penalty.
Practice more Part 3 Return Preparer Rules and Penalties questions
Exam-style questions with worked answers, then full timed mocks. Free to start.
Build a daily practice habit — a few exam-style questions a day, with worked answers. Free to start.
Start practicing →Original study material mapped to the public IRS SEE content outlines; not a real exam question.Not affiliated with or endorsed by the IRS or PSI. Verify figures and rules against current guidance before relying on them.