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authority for a position even where it is supported only by a
well-reasoned construction of the pertinent statutory provision
as applied to the relevant facts. See sec. 1.6662-4(d)(3)(ii),
Income Tax Regs. There may be substantial authority for more
than one position with respect to the same item. See sec.
1.6662-4(d)(3)(i), Income Tax Regs.
The accuracy-related penalty under section 6662(a) does not
apply to any portion of an underpayment if it is shown that there
was reasonable cause for such portion and that the taxpayer acted
in good faith. See sec. 6664(c)(1). The determination of
whether a taxpayer acted with reasonable cause and in good faith
depends on the pertinent facts and circumstances, including the
taxpayer's efforts to assess his or her proper tax liability, the
knowledge and experience of the taxpayer, and the reliance on the
advice of a professional, such as an accountant. See sec.
1.6664-4(b)(1), Income Tax Regs. In the case of claimed reliance
on the accountant who prepared the taxpayer's tax return, the
taxpayer must establish that correct information was provided to
the accountant and that the item incorrectly claimed or reported
in the return was the result of the accountant's error. See Ma-
Tran Corp. v. Commissioner, 70 T.C. 158, 173 (1978).
We have held above that petitioners have failed to show that
they are entitled to nonrecognition treatment under section 1031
and under section 1033. Moreover, petitioners adduced no evi-
dence and make no argument with respect to the various other
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