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at issue and testified he is knowledgeable on taxes and that he
advised the brothers to make the reciprocal transfers.
Respondent's counsel asked no questions on cross-examination.
The record demonstrates that the brothers relied on that advice,
and we conclude that reliance was reasonable under the
circumstances. We hold that Larry and John are not liable for
the accuracy-related penalty.
As to Kathy and Sandra, however, we find no such reliance.
Their gift tax returns were separate from their husbands', and we
must look to whether they exercised due care or whether
reasonable cause existed as to their returns. Neither Kathy nor
Sandra appeared for trial, and there is no evidence in this
record as to what steps they took to ensure their returns were
proper. Although all of the brothers testified at trial, none of
them mentioned Kathy or Sandra in their testimony, and there was
no suggestion that the brothers conveyed to Kathy and Sandra what
transpired at any of the meetings with Kaplan.6 We are unable to
find on this record that either Kathy or Sandra relied on the
advice of Kaplan or any other professional. We sustain
respondent's determinations as to Kathy and Sandra.
Respondent also determined in the notices of transferee
liability for 1992 that Kathy, Sandra, and Diane are liable for
6On brief, petitioners' requested findings of fact on the
issue of reasonable reliance relate only to the four brothers,
and there is no mention of any reliance by Kathy or Sandra.
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