- 49 -
issues.” Id.
On brief, petitioners in each of these consolidated cases
indicate that they are not disputing certain determinations in
petitioners’ respective notices that gave rise to a portion of
the respective deficiencies that respondent determined. We have
sustained the remaining determinations in petitioners’ respective
notices that petitioners in each of these cases have contested
and that gave rise in large part to the respective deficiencies
that respondent determined. As a result, the deficiency determi-
nations in petitioners’ respective notices are sustained in full.
On the record before us, we find that there are substantial
understatements of tax in petitioners’ respective returns for
1999. On that record, we find that respondent has satisfied
respondent’s burden of production under section 7491(c).
Petitioners argue that respondent’s determinations under
section 6662(a) are wrong because “KQC made a good faith and
reasonable effort to obtain qualified professional advice regard-
ing its ability to claim a tax deduction for the charitable
contribution and the requirements to sustain that deduction.”20
(We shall refer to that argument as petitioners’ professional
advice argument.) On the record before us, we reject petition-
ers’ professional advice argument. On that record, we find that
20Petitioners in each of these cases advance no argument
with respect to the portions of the underpayments in petitioners’
respective returns for 1999 that are attributable to determina-
tions in the respective notices that petitioners do not dispute.
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