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if, under all of the facts and circumstances, the reliance was
reasonable and the taxpayer acted in good faith. Sec. 1.6664-
4(b)(1), Income Tax Regs. Considering all the facts and
circumstances presented, we do not find persuasive petitioner's
defense that he relied on his accountant to correctly prepare his
returns. The accountant did not testify. And we found
petitioner's self-serving testimony in this regard to be not
credible. In conclusion, we hold that petitioners are liable for
the accuracy-related penalty on the entire underpayment for 1989,
1990, and 1991.
To reflect the foregoing and because of the increased
deficiency for 1988,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011