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addressed in this opinion or that they adequately disclosed all
relevant facts as to the tax treatment of those items on their
returns. Rather, they contend only that they relied on their
accountant for the preparation of their returns. Thus, in
effect, petitioners argue that they had reasonable cause and
acted in good faith in treating the items as they did on their
returns.
As we discussed above in relation to the accuracy-related
penalty for negligence, petitioners have failed to establish that
the overstatement of deduction items or the understatement of
income items that they conceded before or after trial or that we
addressed in this opinion resulted from a good faith reliance on
the advice of their tax preparer. Consequently, they have failed
to carry their burden of proving that they are not liable for the
accuracy-related penalty for substantial understatements of
income for 1989, 1990, or 1993. Accordingly, we sustain
respondent’s determination to the extent the Rule 155 computation
for 1989, 1990, and 1993 indicates a substantial understatement
of petitioners’ income tax within the meaning of section 6662(d).
Conclusion
We have carefully considered all remaining arguments made by
petitioners for a result contrary to that expressed herein and,
to the extent not discussed above, find them to be irrelevant or
without merit.
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