- 44 -
keeping was generally unbusinesslike, careless, and sloppy.
Petitioners also failed to present any substantive
evidence to support their contention that they provided
their accountant with complete and accurate books and
records and acted reasonably and in good faith reliance on
his advice. In fact, Mr. Jackson testified that he relied
on petitioners to correctly categorize their expenditures
for tax purposes. Accordingly, we sustain respondent's
imposition of the additions to tax for negligence with
respect to petitioners' 1987 and 1988 returns.
In light of the foregoing,
Decisions will be entered
under Rule 155.
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