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expenses that petitioners claimed in petitioners’ 1998 return,
that deduction is not supported by the Code, the regulations, or
the caselaw. See sec. 162(a); sec. 1.162-1(a), Income Tax Regs.;
Levy v. Commissioner, supra at 554; Universal Oil Prods. Co. v.
Campbell, supra at 475.
On the record before us, we find that respondent has satis-
fied respondent’s burden of production under section 7491(c) with
respect to the accuracy-related penalties under section 6662(a)
determined in the notice.
The accuracy-related penalty under section 6662(a) does not
apply to any portion of an underpayment if it is shown that there
was reasonable cause for, and that the taxpayer acted in good
faith with respect to, such portion. Sec. 6664(c)(1). The
determination of whether the taxpayer acted with reasonable
cause, or in good faith, depends on the pertinent facts and
circumstances, including the taxpayer's efforts to assess such
taxpayer’s proper tax liability, the knowledge and experience of
the taxpayer, and the reliance on the advice of a professional,
such as an accountant. Sec. 1.6664-4(b)(1), Income Tax Regs.
Petitioners argue that they had reasonable cause for, or
acted in good faith in, claiming the respective depreciation
deductions in petitioners’ 1997 return and petitioners’ 1998
return with respect to the computer simulator because that
simulator was a unique piece of equipment, and petitioners’
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