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taxpayer from the negligence addition, the reliance must be
reasonable, in good faith, and based upon full disclosure. Id.;
Weis v. Commissioner, 94 T.C. 473, 487 (1990); Pritchett v.
Commissioner, 63 T.C. 149, 174-175 (1974).
Not only have petitioners failed to establish that their
reliance was based on full disclosure, reasonable, and in good
faith, they have fallen short in their attempt to establish that
they relied upon the advice of a tax professional. No testimony
or other evidence as to advice relied upon by petitioners was
advanced. No accountant responsible for preparing petitioners'
return was called. Petitioners merely contend that they relied
upon an accountant to complete their tax returns.
On this record, we conclude that any reliance maintained by
petitioners is not sufficient to shield them from liability for
the negligence addition. Accordingly, respondent's determination
as to this issue is sustained.
Issue 5. Addition to Tax, Sec. 6661
Respondent determined that petitioners are liable for the
addition to tax pursuant to section 6661 for taxable year 1988
due to a substantial understatement of income tax. Respondent's
determination carries with it the presumption of correctness.
Rule 142(a).
The addition to tax is 25 percent of any underpayment
attributable to a substantial understatement. Sec. 6661(a);
Pallottini v. Commissioner, 90 T.C. 498 (1988). A substantial
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