-12- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011