-17-
justify reliance or that Mr. and Mrs. Breeding provided the
preparer all relevant information. See Neonatology Associates,
P.A. v. Commissioner, supra. We therefore do not find that Mr.
and Mrs. Breeding have shown that it was reasonable to rely on
this tax return preparer.
After considering all of the facts and circumstances, we
find that Mr. and Mrs. Hargrove and Mr. and Mrs. Breeding have
failed to establish that they had reasonable cause and acted in
good faith with respect to their respective underpayments.
Accordingly, we sustain respondent’s determination as to Mr. and
Mrs. Hargrove and Mr. and Mrs. Breeding for the accuracy-related
penalties for the relevant years.
We have considered all remaining arguments the parties made
and, to the extent not addressed, we conclude they are
irrelevant, moot, or meritless.
To reflect the foregoing and the concessions of the parties,
Decisions will be entered
for respondent in Docket Nos.
16441-04, 16442-04, 16444-04,
and 16448-04. Decision will
be entered for respondent in
Docket No. 16443-04 with
respect to the deficiencies
and for petitioners with
respect to the section 6662(a)
penalties.
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