Sarkis N. and Baka S. Balabanian - Page 15

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               Petitioners argue that they should not be liable for the               
          penalty because "They held a good faith belief that the check               
          exchange did not involve income to them."  The facts of this case           
          belie any claim of good faith on petitioners’ part.  Their                  
          bookkeeper/tax return preparer advised petitioners that any                 
          excess in their favor at the end of the year was taxable income.            
          Also, petitioners failed to report any of the interest and/or               
          broker fees either paid or credited to them by M&L.  Finally,               
          petitioners did not keep adequate books and records, and the bank           
          deposits analysis shows a substantial understatement of income.             
          Accordingly, we hold that the entire underpayment is subject to             
          the section 6662 penalty.                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered for             
                                        respondent.                                   





















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