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cause and in good faith. See sec. 6664(c). Whether a taxpayer
acted with reasonable cause and in good faith is measured by
examining the relevant facts and circumstances, and most
importantly, the extent to which he or she attempted to assess
the proper tax liability. See Neely v. Commissioner, 85 T.C. 934
(1985); Stubblefield v. Commissioner, T.C. Memo. 1996-537; sec.
1.6664-4(b)(1), Income Tax Regs.
Petitioners argue that they provided all relevant
information to their tax return preparer, Gendron & Co.
Petitioners, however, have provided no testimony concerning the
information they gave to their return preparer. No employee from
Gendron & Co. testified at trial. Additionally, we have found
that petitioner failed to maintain adequate records related to
the claimed net operating losses. Therefore, we find the
underpayment attributable to negligence or disregard of rules or
regulations.
We conclude that petitioners are liable for a penalty
pursuant to section 6662 for 1994, 1995, 1996, 1997, 1998, and
1999.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not
mentioned above, we find them to be irrelevant or without merit.
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