William and Shirley Pratt - Page 23

                                       - 23 -                                         
          were not accurate.  Thus, we find that petitioner did not                   
          reasonably rely on J.E. & Assoc.                                            
               We conclude that for 1995 petitioner did not have reasonable           
          cause or act in good faith.  Accordingly, we hold that petitioners          
          are liable for the penalty pursuant to section 6662(a) for 1995.            
               We have considered all other arguments made by the parties and         
          find those arguments not discussed herein to be without merit.              
               To reflect the foregoing,                                              


                                                   An appropriate order of           
                                             dismissal and decision will be           
                                             entered.                                 

Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23