Franklin D. and Sandra M. Terrell - Page 8

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          demonstrate reasonable cause if he can show that he relied in               
          good faith on a qualified adviser after full disclosure of all              
          necessary and relevant information, see Jackson v. Commissioner,            
          86 T.C. 492, 539-540 (1986), affd. 864 F.2d 1521 (10th Cir.                 
          1989); Paula Constr. Co. v. Commissioner, 58 T.C. 1055, 1061                
          (1972), affd. without published opinion 474 F.2d 1345 (5th Cir.             
          1973); sec. 1.6664-4(b)(1), Income Tax Regs., and that the                  
          incorrect returns resulted from the preparer's error, see Enoch             
          v. Commissioner, 57 T.C. 781, 803 (1972).                                   
               In this case, petitioners have failed to establish that they           
          fully disclosed all necessary and relevant information to Mr.               
          Still or that the incorrect returns were a result of Mr. Still's            
          errors.  Thus, petitioners' negligence was not due to reasonable            
               Accordingly, we sustain respondent's determination that                
          petitioners are liable for the accuracy-related penalty under               
          section 6662(a) for their 1991, 1992, and 1993 taxable years.               
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered under Rule 155.             

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