- 21 -
respect to such portion. Sec. 6664(c)(1); Tippin v.
Commissioner, 104 T.C. 518, 533-534 (1995). In general, the
determination of whether a taxpayer acted with reasonable cause
and in good faith depends upon the pertinent facts and
circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs. The
crucial factor is the extent of the taxpayer's effort to assess
his proper tax liability. Id.
Petitioners make no argument that they had substantial
authority, or that they adequately disclosed the relevant facts,
with respect to the deduction on their tax return. However,
petitioners do summarily opine that they should not be liable for
the section 6662(a) penalty insofar as petitioner "acted under
the advice of Attorneys and Certified Public Accountants".
Reliance on professional tax advice constitutes reasonable
cause only if the taxpayer acted in good faith and made full
disclosure of all relevant facts to the adviser. See Paula
Constr. Co. v. Commissioner, 58 T.C. 1055, 1061 (1972), affd.
without published opinion 474 F.2d 1345 (5th Cir. 1973); sec.
1.6664-4(b), Income Tax Regs. Petitioners did not call any of
petitioner's lawyers or accountants as witnesses. Thus, no
evidence has been proffered pertaining to the information
petitioner may have provided them in soliciting their advice.
See Droz v. Commissioner, T.C. Memo. 1996-81. While the record
includes a letter from King in which he concludes that the "debt"
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