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We conclude that petitioners did not make a good faith
effort to ascertain their tax liabilities for the years in issue,
that it was not reasonable for them to rely on Dunning, and that
they are liable for the addition to tax for substantial
understatement under section 6662(a) for 1997 and 1998.
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
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