- 32 - Klieger v. Commissioner, T.C. Memo. 1992-734; sec. 1.6661-6, Income Tax Regs. Even if petitioners had requested a waiver under section 6661(c), the record demonstrates that they failed to act reasonably and in good faith in deducting the claimed loss from San Nicholas. Petitioner’s limited discussions with Mr. Kellen, a promoter of other, similar jojoba partnerships and a close personal friend and business associate of U.S. Agri’s president, are insufficient to demonstrate reasonable cause and good faith. Similarly, petitioners’ failure to establish the extent of any tax advice received, as well as the basis on which such advice may have been rendered, is further evidence of petitioners’ lack of reasonable cause and good faith. See DePlano v. Commissioner, T.C. Memo. 1998-303. In view of the foregoing, we hold that petitioners are liable for the addition to tax under section 6661(a) for substantial understatement of tax liability. Respondent’s determination is sustained.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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