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herein, we find that petitioners had no reasonable basis for
having used the losses relating to petitioner's rental activity
at Crestwood that they reported in their Federal income tax
returns for 1989 and 1990 to offset their reported income from
other sources for those years. See, e.g., Cramer v. Commis-
sioner, 101 T.C. 225, 254 (1993), affd. 64 F.3d 1406 (9th Cir.
1995); Grant v. Commissioner, 84 T.C. 809, 827 (1985), affd.
without published opinion 800 F.2d 260 (4th Cir. 1986).
On the instant record, we find that petitioners have not
established that they acted with reasonable cause and in good
faith when they used the reported losses from petitioner's rental
activity at Crestwood to offset nonpassive income. We therefore
sustain respondent's determination imposing the accuracy-related
penalty on petitioners for each of the years 1989 and 1990.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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