Alton M. Towles, Jr. - Page 12




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               Petitioners contend that they are not liable for each of the           
          years at issue for the accuracy-related penalty under section               
          6662(a) on the underpayment of tax for each such year that is               
          attributable to the deductions with respect to the Paradise Lane            
          property that they claimed in their returns for those years.  On            
          the record before us, we find that petitioners have failed to               
          establish that they had reasonable cause and that they acted in             
          good faith in claiming those deductions.  See sec. 6664(c)(1);              
          sec. 1.6664-4(a) and (b), Income Tax Regs.  We further find on              
          that record that petitioners have failed to show that they are              
          not liable for each of the years at issue for the accuracy-                 
          related penalty under section 6662(a) on the underpayment of tax            
          for each such year that is attributable to the deductions with              
          respect to the Paradise Lane property that they claimed in their            
          1994 and 1995 returns.                                                      
               To reflect the foregoing and the concessions of the parties,           
                                             An Order denying petitioners'            
                                        motion to strike testimony will be            
                                        issued, and decision will be                  
                                        entered under Rule 155.                       












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