- 22 -
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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