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    37 -

as to the tax treatment of an item may meet

Sec. 1.6664-4(b), Income Tax Regs.

Petitioner has made no showing that he

attempt to comply with the tax rules and re

to those deductions he took for the years a

been

disallowed.

Hence,

with

respect

to

th

petitioner has failed to show that he was n

Moreover, petitioner has not shown that he

with respect to, or that there was reasonab

position

he

took.

Further,

petitioner

does

relied on a tax professional as to the tax

expenses and losses at issue, including tho

personal

residences.

Petitioner

simply

ass

accuracy-related penalty does not apply bec

claimed the deductions under section 162(a)

the contrary.

Under these circumstances, we are comp

petitioner is liable for the accuracy-relat

years at issue.

this requirement.

made a reasonable

gulations with regard

t issue which have

ose deductions,

ot negligent.

acted in good faith

le cause for, the

not claim that he

treatment of the

se related to his

erts that the

ause he properly

.

We

have

found

to

elled to hold that

ed penalty for the

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