Dennis L. Rogers and Charlotte Rogers - Page 15

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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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