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determination is presumed correct, and petitioner bears the
burden of proving otherwise. Rule 142(a); Luman v. Commissioner,
79 T.C. 846, 860-861 (1982).
In the instant case, petitioner argues that he informed his
return preparer, Mr. Tilton, of the sale of the automobiles on
behalf of the Ben-Jabr family and the loans he received in 1988.
Petitioner contends that Mr. Tilton advised him that the receipt
of the loan proceeds was not taxable. Petitioner claims that his
alleged reliance on Mr. Tilton's advice was reasonable, and he
acted in good faith in not including the proceeds from the sale
of the automobiles in his gross income for 1988.
However, we have already found that the five automobiles in
issue belonged to petitioner. The information that petitioner
allegedly gave to Mr. Tilton was not accurate, and, therefore,
any advice based on this inaccurate information cannot be relied
upon by petitioner to shield him from the addition to tax for
negligence. We also note that petitioner failed to report gain
on his 1988 return from the sale of two additional automobiles
which he admittedly owned. Petitioner has failed to present any
credible evidence demonstrating that he was not negligent, and,
therefore, we sustain the addition to tax.
Finally, respondent determined that petitioner is liable for
an addition to tax for substantial understatement of income tax.
Section 6661(a) provides for an addition to tax equal to 25
percent of the amount of any underpayment attributable to such
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