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in that petitioner had no formal education beyond high school.
While a lack of any significant formal education beyond high
school has been a factor in some cases where we have found that
taxpayers were not negligent under section 6653, such cases are
exceptions rather than the norm. For examples of cases in which
we have held the taxpayers negligent despite their modest formal
education, see Singer v. Commissioner, T.C. Memo. 1997-325
(taxpayer, who worked with success in the floor covering
business, quit high school during his sophomore year); Estate of
Hogard v. Commissioner, T.C. Memo. 1997-174 (taxpayer, an owner
of a business involving coin-operated entertainment machines, had
a high school education), affd. without published opinion sub
nom. Gilmore & Wilson Constr. Co. v. Commissioner, 166 F.3d 1221
(10th Cir. 1999); McPike v. Commissioner, T.C. Memo. 1996-46
(taxpayer, a firefighter, received no formal education beyond
high school, except for a few courses in fire science); Lax v.
Commissioner, T.C. Memo. 1994-329 (taxpayer, who spent his entire
working career in the textile business, had no formal post-high
school education), affd. without published opinion 72 F.3d 123
(3d Cir. 1995); Klieger v. Commissioner, T.C. Memo. 1992-734
(several of the taxpayers had only high school educations);
Gerber & Associates, Inc. v. Commissioner, T.C. Memo. 1987-446
(no formal post-high school education), affd. without published
opinion 876 F.2d 106 (7th Cir. 1989).
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