S. Victoria Wells - Page 15

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          identify, the potential controversy here; that is, the amount of            
          gain petitioner was required to report.  We hold that petitioner            
          has adequately disclosed the relevant facts relating to the sale            
          of the Paddock Lane property and that she is not liable for the             
          accuracy-related penalty under section 6662(a).                             
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               
































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