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from petitioner's rental activity at Crestwood to offset nonpas-
sive income. Moreover, although petitioner is not a tax special-
ist, he is highly educated and is a sophisticated businessman.
He had invested in several tax shelters in the past that were
challenged by the Service. In fact, petitioner had specific
knowledge of the limitations imposed on the deductibility of
losses sustained from his rental activity at Crestwood because he
was informed of those limitations during the board meeting held
in January 1988. Based on our review of the instant record, we
find that petitioners have failed to establish that any reliance
by them on the advice of their accountant was reasonable or in
good faith.
Petitioners further claim that they are not liable for the
years at issue for the accuracy-related penalties under section
6662(a) because the facts and circumstances relating to petition-
er's involvement in his rental activity at Crestwood establish
that he materially participated in that activity. On the instant
record, we find that application of section 469 and the pertinent
regulatory provisions to the facts surrounding petitioner's
involvement in his rental activity at Crestwood would not have
enabled petitioners to conclude reasonably that that involvement
rose to the level of material participation during each of the
years at issue. We also note that we have held section 1.469-
5T(a)(1), Temporary Income Tax Regs., 53 Fed. Reg. 5725 (Feb. 25,
1988), which petitioners challenge, to be valid. On the record
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