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from the instant case, and their reliance on those authorities is
misplaced.26 On the record before us, we reject petitioners’
substantial authority argument as it relates to Mr. Hopkins’s S
Corporation’s claimed advertising expense deduction of $3,130 and
Mr. Hopkins’s S Corporation’s claimed promotional expense deduc-
tion of $39,000.
On the record before us, we find that petitioners have
failed to carry their burden of establishing that there was
reasonable cause for, and that they acted in good faith with
respect to, any portion of the underpayment for petitioners’
taxable year 1999.
Based upon our examination of the entire record in this
case, we find that petitioners have failed to carry their burden
of establishing that they are not liable for 1999 for the accu-
racy-related penalty under section 6662(a).27
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
irrelevant, moot, and/or without merit.
To reflect the foregoing and the concessions of petitioners,
26See supra note 19.
27In light of our finding that petitioners are liable for
the year at issue for the accuracy-related penalty because of a
substantial understatement of tax under sec. 6662(b)(2), we shall
not address respondent’s argument that petitioners are liable for
that year for that penalty because of negligence or disregard of
rules or regulations under sec. 6662(b)(1).
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