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Such authorities are not on point. We have found that the
corporation did not engage in any trade or business in 1988 (or
in 1989 or 1990). In part, we did so in reliance on petitioners'
agreement that the corporation's receipts and verifiable expenses
for 1988 properly were allocable to the trade or business of
Scott's Limo. Petitioners have adduced no authority, substantial
or otherwise, to support deductions on the facts as we have found
them and as, apparently, petitioners have agreed to them.
Finally, in the petition, petitioners aver as a fact, in
support of their assignment that respondent erred in determining
penalties under section 6662, that "petitioners acted in good
faith in reliance on professional advice in filing their returns
as they did and had a reasonable basis for and belief in the
accuracy of said returns." Respondent denies that averment. We
assume that petitioners meant to invoke the reasonable cause
exception of section 6664(c)(1). However, petitioners do not
mention section 6664(c)(1) in their opening brief and, in their
reply brief, state only: "the facts demonstrate that petitioners
come within the provisions of I.R.C. � 6664 and are entitled to
relief thereunder." Apparently, the facts that petitioners rely
on are that "petitioners and their accountant clearly made a good
faith effort to determine their true tax liabilities for the
years at issue." Petitioners have not particularized the
portions of the 1989 and 1990 underpayments with respect to which
they claim to have acted with reasonable cause and in good faith.
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