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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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Last modified: May 25, 2011