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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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