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have raised other questions. Petitioners clearly did not make a
reasonable effort to determine whether the representations of Mr.
Beltran were correct. They did not consult other tax
professionals to verify the accuracy of the returns prepared by
Mr. Beltran or the representations he made to them regarding
their deductions. The Court is satisfied from the record that
Mr. Beltran knew, or had reason to know, all the relevant facts
upon which, had he been a qualified professional, he could have
accurately advised petitioners on the amount of their allowable
deductions. Mr. Beltran listed unrealistic amounts as deductions
on petitioners' returns. The Court is further satisfied that
petitioners knew they were required under the law to substantiate
deductions claimed on their returns. The questions they raised
with Mr. Beltran and the answers he gave them should have
prompted them to look beyond and ascertain the accuracy of his
representations. Petitioners, therefore, made no effort to
assess their tax liabilities correctly. On this record, the
Court sustains respondent on the section 6662(a) accuracy-related
penalties for the years in question.
Section 6673(a) authorizes the Court to require a taxpayer
to pay to the United States a penalty not exceeding $25,000 when,
in the Court's judgment, proceedings have been instituted or
maintained by the taxpayer primarily for delay or where the
taxpayer's position in the proceeding is frivolous or groundless.
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