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that he believed that claiming a deduction with respect to such
claimed charitable contribution would be a “push”; that is to
say, Mr. Marceron believed that there was a substantial risk that
respondent would disallow any such claimed deduction.
On the record before us, we find that petitioners in each of
these cases have failed to carry their burden of establishing
that there was reasonable cause for, and that they acted in good
faith with respect to, any portion of the underpayments in
petitioners’ respective returns for 1999.
Based upon our examination of the entire record before us,
we find that petitioners in each of these cases have failed to
carry their burden of establishing that they are not liable for
1999 for the accuracy-related penalty under section 6662(a)
because of a substantial understatement of tax under sec.
6662(b)(2).26
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
26In light of our finding under sec. 6662(a) and (b)(2), we
need not address respondent’s argument that petitioners in each
of these cases are liable for 1999 for the accuracy-related
penalty under sec. 6662(a) because of negligence or disregard of
rules or regulations under sec. 6662(b)(1).
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