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Although an accountant signed petitioners' tax returns for the
years in issue as the preparer, the record does not show that
petitioners relied on their accountant's advice in failing to
file their returns timely and failing to report large amounts of
gross income. Petitioners' tax preparer never testified as to
his tax advice, and petitioners offered no evidence, other than
Mr. Ghadiri's testimony, concerning his tax advice. We find
Mr. Ghadiri's testimony to be unpersuasive on this issue.
For the reasons stated above, we conclude that the entire
underpayment of tax for each year is due to negligence.
Accordingly, we sustain respondent's determination on this issue.
We have considered all arguments made by petitioners for
contrary holdings and, to the extent not discussed above, find
them to be without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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