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and the taxpayer in good faith relied on the advice of a competent
tax preparer. Jackson v. Commissioner, 86 T.C. 492, 539-540
(1986), affd. 864 F.2d 1521 (10th Cir. 1989). Petitioners have not
established that they acted with reasonable cause and in good faith
in relying on their accountants to prepare their tax returns for
the years in issue; they have also failed to demonstrate that they
maintained books and records in accordance with section 6001.
Consequently, we hold that petitioners are liable for the accuracy-
related penalty pursuant to section 6662 for each of the years in
issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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