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Respondent determined that Dr. Ehrenworth negligently
claimed exemptions for Andrew and Robert for 1986 and 1987. We
agree. We believe that it was not reasonable for Dr. Ehrenworth
to believe that he could claim exemptions for Robert and Andrew
for 1986 and 1987 because he did not have custody of them and
the agreement did not allow him to claim these exemptions.
Dr. Ehrenworth does not argue that he had reasonable cause for
claiming exemptions for Robert and Andrew. We treat this as
his concession of this issue. We find that Dr. Ehrenworth was
negligent with respect to the issue of whether he was entitled
to claim exemptions on his 1986 and 1987 tax returns.
Respondent also determined that Mrs. Spector negligently
claimed an exemption for Robert for 1986 because she did not show
that she provided more than $600 of support for him in 1986. We
disagree. Although she did not establish that she provided more
than $600 to support Robert in 1986, she showed that she provided
more than $600 to support him in 1987 and 1988. She claimed the
exemption in good faith. We find that Mrs. Spector was not
negligent in claiming an exemption for Robert for 1986.
2. Substantial Understatement of Income Tax
Respondent determined that petitioners were liable for
additions to tax for substantial understatement of income tax
under section 6661 for 1986, 1987, and 1988. Respondent conceded
that petitioners are not liable for the additions to tax for
substantial understatement for 1986, 1987, and 1988 for any
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