- 48 - 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).Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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