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          understatement is equal to the excess of the amount of tax                  
          required to be shown in the tax return over the amount of tax               
          shown in the tax return, sec. 6662(d)(2)(A), and is substantial             
          in the case of an individual if it exceeds the greater of 10                
          percent of the tax required to be shown or $5,000, sec.                     
          6662(d)(1)(A).                                                              
               The accuracy-related penalty under section 6662(a) does not            
          apply to any portion of an underpayment if it is shown that there           
          was reasonable cause for, and that the taxpayer acted in good               
          faith with respect to, such portion.  Sec. 6664(c)(1).  The                 
          determination of whether the taxpayer acted with reasonable cause           
          and in good faith depends on the pertinent facts and circum-                
          stances, including the taxpayer’s efforts to assess such tax-               
          payer’s proper tax liability, the knowledge and experience of the           
          taxpayer, and the reliance on the advice of a professional, such            
          as an accountant or an attorney.  Sec. 1.6664-4(b)(1), Income Tax           
          Regs.  The determination of whether a taxpayer acted with reason-           
          able cause and in good faith with respect to an underpayment that           
          is related to an item reflected in the return of a passthrough              
          entity is made on the basis of all the pertinent facts and                  
          circumstances, including the taxpayer’s own actions, as well as             
          the actions of the passthrough entity.  Sec. 1.6664-4(e), Income            
          Tax Regs.  Reliance on the advice of a professional does not                
          necessarily demonstrate reasonable cause and good faith unless,             
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