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petitioners' 1986, 1987, and 1988 returns. In any case, Mrs. Zaban
lacks reasonable cause and good faith for each of the years in
issue. Mrs. Zaban never reviewed the returns prepared by Mr.
Fidati and occasionally signed blank returns. Her failure to
review the returns and her blind reliance on Messrs. Zaban and
Fidati were not reasonable. See Bollaci v. Commissioner, T.C.
Memo. 1991-108; Guinn v. Commissioner, T.C. Memo. 1983-401.
Additionally for 1990, Mrs. Zaban admitted that she had reason to
be suspicious of Mr. Fidati's preparation of petitioners' returns
after October 1990, and yet she never reviewed the 1990 return.
See Baugh v. Commissioner, T.C. Memo. 1996-70; Brown v.
Commissioner, T.C. Memo. 1992-15; sec. 1.6664-4(b), Income Tax
Regs.
We conclude that Mrs. Zaban is liable for the additions to tax
for the substantial understatement of tax for 1986 through 1988,
and for the accuracy-related penalty for 1990.
The fact that Mr. Zaban has conceded the fraud additions to
tax for 1986, 1987, and 1988 is irrelevant. Mr. Zaban may be held
liable for both additions to tax for fraud and additions to tax for
substantial understatement of tax for those years. OBRA sec.
7721(a). Thus, we hold that Mr. Zaban is liable for the
substantial understatement additions to tax for 1986 through 1988
and for the accuracy-related penalty for 1990.
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