- 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Last modified: May 25, 2011