Ronald A. and Carol J. Lehrer - Page 9

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          construction business remained consistent.  Petitioners offered             
          no explanation for the reduced income tax reported on the returns           
          other than the change in return preparer.  We cannot excuse a               
          taxpayer who makes little or no effort to discern whether the               
          person the taxpayer has chosen to prepare a return is competent             
          to give tax advice.  We find that petitioners did not act in good           
          faith in relying on Mr. Borrelli’s advice.                                  
               Accordingly, we find that petitioners did not have                     
          reasonable cause for, nor did they act in good faith with respect           
          to, the understatements of income tax.  We therefore sustain                
          respondent’s determination that petitioners are liable for the              
          section 6662(a) penalty for each of the years at issue.                     
          To reflect the foregoing and the concessions of the parties,                

                                                  Decision will be entered            
                                             under Rule 155.                          




















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