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determinations in the notice that petitioners conceded in the
stipulation of settled issues. Consequently, we reject petition-
ers' position that respondent's determinations under section
6662(a) are erroneous because there is no additional tax due for
any of the taxable years for which respondent determined that
petitioners are liable for the accuracy-related penalty under
section 6662(a).
On the record before us, we find that petitioners have
failed to show that there was substantial authority for the
position that they took in the consolidated returns under sec-
tions 1031,13 under section 1033, and with respect to the other
determinations in the notice which petitioners conceded.
As for petitioners' claim that they relied on the advice of
Mr. Riggs, their return preparer, in taking the positions re-
flected in the consolidated returns, the record does not estab-
lish what specific information petitioners allegedly provided to
him. Petitioners did not call Mr. Riggs as a witness. The only
evidence regarding petitioners' reliance on Mr. Riggs is the
following general and conclusory testimony of Mr. Canty:
Well, we put everything in a box and we took it over to
him. We gave him all the information on the sales that
we had and tried to answer all his questions. He took
it all in the back room and did whatever they do -- did
the books, did the tax returns.
13As we previously indicated, we find the cases on which
petitioners rely to support their position under sec. 1031 to be
distinguishable from the present case. Consequently, their
reliance on those cases is misplaced.
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