- 57 -
any of such preparers. Westbrook v. Commissioner, supra; Weis v.
Commissioner, supra; Ma-Tran Corp. v. Commissioner, supra. On
that record, we further find that petitioners have failed to
carry their burden of establishing that they had reasonable cause
for, and that they acted in good faith with respect to, relying
on any advice of Mr. Braun, or any other professional, regarding
the disputed property expenses, the Virginia Beach property
depreciation deductions, the legal fees with respect to the
Mitchums Creek property, and the disputed child care expenses.
See sec. 6664(c)(1).
Based upon our examination of the entire record before us,
we find that each petitioner has failed to show that such peti-
tioner was not negligent and did not disregard rules or regula-
tions within the meaning of section 6662(b)(1), or otherwise did
what a reasonable person would do, with respect to any portion of
the underpayment for any of the years at issue. Based on that
examination, we further find that each petitioner has failed to
show that such petitioner acted with reasonable cause and in good
faith with respect to any portion of the underpayment for any of
the years at issue. See sec. 6664(c). Based upon our examina-
tion of the entire record before us, we find that each petitioner
has failed to establish that such petitioner is not liable for
the years at issue for the accuracy-related penalties under
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