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to guide them in determining the tax treatment of Mr. Enyart’s
receipt of the B&L equipment in exchange for his covenant not to
compete with B&L.
As for petitioners’ claimed reliance on Mr. Fyffe, on the
instant record, we reject that claim. Petitioners have failed to
show what information they provided to Mr. Fyffe in connection
with his preparation of their joint return. In fact, the record
is devoid of any evidence regarding the preparation of that
return and petitioners’ claimed reliance on Mr. Fyffe.
Based on our examination of the entire record before us, we
find that petitioners have failed to establish that they acted
with reasonable cause and in good faith in taking the position
reflected in their joint return with respect to the B&L equip-
ment. We further find on that record that petitioners have
failed to establish any error in respondent’s determination that
they are liable for 1992 for the accuracy-related penalty under
section 6662(a). Consequently, we sustain that determination.
We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concession of petitioners,
Decision will be entered for
respondent.
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