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relied upon that publication for the requirements relating to
record keeping, not for determining whether petitioners' activities
qualified as material participation. Thus, petitioners have failed
to prove that they had substantial authority for reporting material
participation in the Hawaii condominiums. See Swicegood v.
Commissioner, T.C. Memo. 1989-467.
Petitioners offered no testimony with respect to Mrs.
Pohoski's Schedule C expenses relating to her nursing work. Rule
142(a).
Thus, we hold that petitioners are liable for the accuracy-
related penalty, pursuant to section 6662, with respect to the
Molokai condo and Mrs. Pohoski's nursing activities.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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