Max M. and Joan E. Greenberg - Page 12

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          to these payments was patently erroneous.  Petitioners' money was           
          not invested in the manner promised by Pioneer Mortgage.                    
               Because the payments petitioners received from or through              
          Pioneer Mortgage in 1990 represented a return of capital, and not           
          interest income, respondent's determination that petitioners are            
          liable for the accuracy-related penalty falls by the wayside.8              
          Consequently,                                                               

                                                                                     
                                                  Decision will be entered            
                                             for petitioners.                         























               8    Were we required to decide this issue, we would rule in           
          favor of petitioners.                                                       




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