Jose M. Vidaurre and Ana Maria Vidaurre - Page 8

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               Petitioners reported no gain from the sale on their Fort               
          Lauderdale property on their 1990 return.  They assert that they            
          believed they were entitled to the benefits of sections 121 and             
          1034.  However, petitioners' sole basis for believing their gain            
          was nontaxable was a single paragraph contained in a homeowners'            
          brochure.  Their reliance upon the single paragraph was                     
          unreasonable.  They disregarded the rest of the article, which              
          discussed the qualifications for obtaining nonrecognition                   
          treatment of gain on home sales.  Petitioners clearly took the              
          paragraph out of context and presented no further evidence to               
          justify their belief.                                                       
               Based on the record as a whole, we conclude that petitioners           
          have not carried their burden of proving that they acted with               
          reasonable cause.  We hold that petitioners are liable for the              
          accuracy-related penalty under section 6662(a).                             
               To reflect the foregoing and respondent's concessions,                 

                                             Decision will be entered                 
                                        under Rule 155.                               

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