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problems and questions that should have been obvious to any
one of the unitholders, Mr. Gerver failed to note any of
them. For this reason, if Mr. Gerver undertook to advise
petitioner, we do not believe that reliance on his advice
would have been reasonable and in good faith.
For the above reasons, we also reject petitioners'
claim that they are not liable for the substantial under-
statement addition to tax on the ground that they meet the
standard for waiver under section 6661(c). We do not agree
that they have shown either a "reasonable cause for the
understatement" or that they "acted in good faith." Sec.
6661(c).
Finally, we do not agree with petitioners' assertion
that the additions to tax under sections 6653(a) and 6661
should not apply "because the Court's holding in Robertson
I is based upon the novel theory that Petitioner acquired
a limited or partial interest, rather than an entire
ownership interest, in the Computer Equipment."
Petitioners fail to recognize that in Robertson I we were
evaluating the economic substance of the transaction in
order to determine whether the transaction was a sham, as
had been determined by respondent. In that connection,
we noted the limited nature of the interest that had been
acquired by the trust and evaluated the economic substance
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