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          effort made by the Castros and any advisers with whom they may              
          have consulted to ascertain whether the trust structure at issue            
          in these consolidated cases would be respected for Federal income           
          tax purposes.  Absent such proof, we cannot relieve petitioners             
          of liability for the accuracy-related penalties under section               
          6662(a) and (b)(1).  See Neely v. United States, 775 F.2d 1092,             
          1095 (9th Cir. 1985); George v. Commissioner, T.C. Memo. 1999-              
          381; Hanson v. Commissioner, T.C. Memo. 1981-675; sec. 1.6664-              
          4(b)(1), Income Tax Regs.  We sustain respondent’s determination            
          that petitioners are liable for accuracy-related penalties                  
          pursuant to section 6662(a) for 1995 and 1996 on any underpayment           
          of income tax that may be due as a result of this opinion.                  
          V.   Section 6673 Penalty                                                   
               Section 6673(a)(1)(A) and (B) provides that this Court may             
          impose a penalty of up to $25,000 whenever proceedings have been            
          instituted or maintained by the taxpayer primarily for delay, or            
          whenever the taxpayer’s position in a proceeding is frivolous or            
          groundless.  Before trial, respondent warned the Castros that               
          respondent intended to move for a penalty under section 6673 and            
          gave the Castros copies of cases supporting respondent’s                    
          contention that their arguments lacked merit.                               
               We are satisfied that the Castros did not institute or                 
          maintain these proceedings primarily for delay.  The Castros’               
          belief that their trust structure should be respected for Federal           
          income tax purposes was sincere if uninformed by any reasonable             
          analysis of pertinent authority.  In addition, there is no                  
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