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The only evidence that petitioner presented to establish his
reliance on Ms. Caleda’s purported advice was his uncorroborated
and questionable testimony, on which we are unwilling to rely.
Assuming arguendo that we were to accept petitioner’s claim that
he relied on Ms. Caleda’s advice, petitioner has failed to
establish that he supplied correct information to Ms. Caleda and
that the error in his 1998 return in excluding his wage income
from his gross income was the result of Ms. Caleda’s error. In
fact, the record strongly suggests that petitioner provided Ms.
Caleda with incorrect information as to where he resided during
19987 and that the error in petitioner’s return was the result of
that incorrect information and not Ms. Caleda’s error.
On the instant record, we find that petitioner has failed to
show that he was not negligent and did not disregard rules or
regulations within the meaning of section 6662(b)(1), or other-
wise did what a reasonable person would do, with respect to the
underpayment for the year at issue. On that record, we further
find that petitioner has failed to show that he acted with
reasonable cause and in good faith with respect to the underpay-
7In this connection, petitioner attached Form 4563 to his
1998 return in which he claimed, inter alia, that he resided in
American Samoa throughout 1998. Nowhere in that form did peti-
tioner indicate that he resided and worked in Johnston Island
throughout that year. Information about where petitioner resided
during 1998 is information that petitioner would have provided to
Ms. Caleda, and he evidently misinformed her about the location
of his residence during that year.
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