Thomas M. and Christine A. Fries - Page 22

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          is uncollectible, petitioner has not established whether he fully           
          divulged all relevant facts to King.                                        
               Based on our review of the record, we find that petitioners            
          have failed to demonstrate that petitioner's reliance on the                
          advice of his lawyers and accountants was reasonable or that he             
          acted in good faith.  Accordingly, we sustain respondent's                  
          determination that petitioners are liable for the accuracy-                 
          related penalty with respect to the entire underpayment for 1989.           
              To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             for respondent.                          


























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