Paul R. Peete - Page 8

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          that the hospital visits were in connection with his position as            
          a reverend.                                                                 
               Petitioner was open and candid at trial regarding his                  
          involvement in the pyramid scheme.  Unfortunately for petitioner,           
          his own testimony clearly establishes that he did not have                  
          reasonable cause and did not act in good faith in claiming the              
          Schedule C loss.  Petitioner was unaware of certain items claimed           
          as expenses on the return, he knew that some of the claimed                 
          deductions were too good to be true, and he failed to investigate           
          the appropriateness of the claimed deductions after learning that           
          his tax return preparer was being investigated in connection with           
          the same activity.  Petitioner failed to call Ms. Manasseh or any           
          other witnesses at trial to corroborate his claim of good faith             
          reliance, and his testimony indicates that he did not rely on the           
          advice of an independent, competent tax professional.                       
          Accordingly, we hold that petitioner is liable for the accuracy-            
          related penalty.                                                            

                                                  Decision will be entered            
                                             under Rule 155.                          













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