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          Petitioners have conceded the deficiencies in tax as determined             
          by respondent.  Petitioners understated gross receipts on their             
          Schedule C, Profit or Loss From Business, for all the years in              
          issue.  Petitioners have conceded that they understated gross               
          receipts by $267,273 for 2003, which amount was nearly half of              
          the actual gross receipts in that year.                                     
               Under section 6662, a taxpayer may be liable for a penalty             
          of 20 percent on the portion of an underpayment of tax                      
          attributable to a substantial understatement of tax.  Sec.                  
          6662(a).  The term “substantial understatement” is defined as the           
          greater of 10 percent of the tax required to be shown on the                
          return for the taxable year or $5,000.  Sec. 6662(d).  However,             
          the accuracy-related penalty is not imposed with respect to any             
          portion of the understatement as to which the taxpayer acted with           
          reasonable cause and in good faith.  Sec. 6664(c)(1); Higbee v.             
          Commissioner, 116 T.C. 438, 448-449 (2001).  The decision as to             
          whether the taxpayer acted with reasonable cause and in good                
          faith depends upon all the pertinent facts and circumstances.               
          Sec. 1.6664-4(b)(1), Income Tax Regs.  Relevant factors include             
          the taxpayer’s efforts to assess his proper tax liability,                  
          including the taxpayer’s reasonable and good faith reliance on              
          the advice of a tax professional.  See id.                                  

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