Thai V. Pham and Khuy T. Bui - Page 19

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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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