- 38 -                                         
          trial, that petitioners’ professed reliance on Gordon, Kabeck,               
          Krickstein, and petitioner’s other medical colleagues was not                
          reasonable.  Accordingly, we regard Thompson v. Commissioner,                
          supra, as distinguishable from the present cases.                            
               In Klein v. United States, supra, the District Court denied             
          the Government’s motion for summary judgment on the issue of the             
          taxpayers’ liability for additions to tax for negligence.  The               
          District Court held that on the record before it, the issue of               
          negligence could not be decided as a matter of law but rather was            
          an issue to be decided by the trier of fact.                                 
               In the present cases, we have addressed the issue of                    
          negligence as an issue of fact, which we have decided based on               
          the totality of the facts and circumstances presented at trial.              
          Thus, Klein v. United States, supra, is distinguishable from the             
          present cases.                                                               
               Upon consideration of the entire record, we hold that                   
          petitioners are liable for the additions to tax for negligence               
          under section 6653(a)(1) and (2).  Respondent is therefore                   
          sustained on this issue.                                                     
          II. Section 6621(c) Additional Interest                                      
               Section 6621(c), formerly section 6621(d), provides for                 
          additional interest in the form of an increased rate of interest             
          (i.e., 120 percent of the normal rate under section 6601) on an              
          underpayment of tax, but only if such underpayment exceeds $1,000            
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