Bryan J. and Christine N. Baugh - Page 14

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          that 414 and 414-1/2 Monroe were both being treated as rental               
          properties, a cursory review of the returns would have provided             
          petitioners with such knowledge.  Line 1A of Schedule E,                    
          Supplemental Income and Loss, on the 1990 and 1991 returns and              
          line 1B of Schedule E, Supplemental Income and Loss, on the 1992            
          return clearly state “DUPLEX - 414 & 414.5 MONROE ST” as the kind           
          and location of petitioners’ rental real estate property.  A                
          review of the returns in question would have also shown the                 
          duplicate deductions taken in 1990 for mortgage interest and in             
          1990 and 1991 for real estate taxes.  Failure to review the                 
          returns prepared for them by another is itself negligence.  Metra           
          Chem Corp. v. Commissioner, supra at 662; Bailey v. Commissioner,           
          21 T.C. 678, 687 (1954).                                                    
               Petitioners have not established reasonable cause or good              
          faith reliance to excuse themselves from the penalties for                  
          negligence or intentional disregard of rules or regulations.  See           
          Mack v. Commissioner, T.C. Memo. 1995-482.                                  
               To reflect the foregoing and concessions of the parties,               
                                                  Decision will be entered            
                                             under Rule 155.                          












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