Reaves Livestock, Inc., et al. - Page 48

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               Petitioners contend that respondent should waive this                  
          addition to tax because they relied on professional advice and              
          acted in good faith.  Sec. 6661(c); see Mailman v. Commissioner,            
          91 T.C. 1079, 1082-1084 (1988).  We disagree for reasons stated             
          at par. C-4, above.  The mistakes on their return were not Davis'           
          fault.  Petitioners did not convince us that they acted in good             
          faith in failing to report income from the 282 checks,                      
          withdrawals from the First Citizens accounts for personal                   
          purposes, and the John Chavis checks.                                       
               Reaves Livestock did not give Davis all of the information             
          about the 282 checks, the First Citizens accounts, and the John             
          Chavis checks.  Thus, the mistakes on the Reaves Livestock                  
          returns were not his fault.                                                 
               We conclude that Mr. and Mrs. Reaves and Reaves Livestock              
          are liable for the addition to tax for substantial understatement           
          of tax for 1984, 1985, 1986, and 1987, if calculations under Rule           
          155 show that the understatements are substantial for purposes of           
          section 6661(a).                                                            
















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