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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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