Gary D. and Johnean F. Hansen - Page 20

                                       - 20 -                                         
          the returns, and she assumed the items were therefore correct.              
          Petitioners did not have the returns reviewed by an accountant or           
          anyone else outside the Hoyt organization prior to signing them.            
               The section 6662(a) accuracy-related penalty in this case is           
          derived solely from the loss that petitioners claimed in 1991               
          with respect to DSBS 87-C.  Respondent issued a Notice of Final             
          Partnership Administrative Adjustment (FPAA) to petitioners with            
          respect to DSBS 87-C that reflected the disallowance of various             
          deductions claimed on the partnership return for its taxable year           
          ending in 1991.  Because a timely petition to this Court was not            
          filed in response to the FPAA issued for DSBS 87-C, respondent              
          made a computational adjustment assessment against petitioners              
          with respect to the FPAA.  The computational adjustment of                  
          $40,892 changed petitioners’ claimed DSBS 87-C loss of $32,306 to           
          income of $8,586, increasing petitioners’ tax liability by                  
          $7,724, from $799 to $8,523.3  In the notice of deficiency                  
          underlying this case, respondent determined that petitioners are            
          liable for the section 6662(a) accuracy-related penalty for                 
          negligence or disregard of rules or regulations with respect to             
          the entire amount of the underpayment resulting from the DSBS 87-           
          C computational adjustment.                                                 


          3The amount of the farm income reported by petitioners on                   
          their 1991 return was not changed by respondent pursuant to the             
          computational adjustment assessment, presumably because the farm            
          income was not a partnership item.                                          





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