A New York State Administrative Law Judge has denied a request for abatement of penalties imposed in connection with underpayment of personal income tax, rejecting the taxpayers’ claims that they reasonably relied on the advice of their accountant. Matter of Surinder and Aruna Pal, DTA No. 825976 (N.Y.S. Div. of Tax App., Oct. 1, 2015). The ALJ found that the Pals, both physicians, had been suspicious of the advice they received, since it resulted in an abrupt increase in the amount of their refunds, and even tried to do their own research, but nevertheless continued to rely on that advice and never consulted another tax professional or the Department. Therefore, their continued reliance on such professional advice was found not to constitute reasonable cause under the circumstances for setting aside the imposition of penalties.