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factors include the taxpayer’s efforts to assess his or her
proper tax liability, including the taxpayer’s reasonable and
good faith reliance on the advice of a tax professional. See
id.; see also sec. 1.6664-4(c), Income Tax Regs.
The record in these cases negates any mitigation by
reasonable cause. Petitioners’ failure to maintain adequate
books and records constitutes negligence, particularly when that
failure resulted in substantial underreporting of income. See
sec. 6662(c). Bradshaw handled only part of petitioners’ income-
producing activities. Petitioners did not take Bradshaw’s advice
that corporate funds should not be deposited in their personal
bank accounts. They did not provide to him accurate and complete
information concerning income. We do not believe that they
relied on him reasonably or in good faith. Accordingly, the
accuracy-related penalties determined by respondent are
sustained.
We have considered the arguments of the parties that were
not specifically addressed in this opinion. Those arguments are
either without merit or irrelevant to our decision.
To reflect the foregoing and the concessions of the parties,
Decisions will be entered
under Rule 155.
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