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alternative, whether petitioners are liable for the accuracy-
related penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference.
Background
Petitioners, Richard K. McGirl (Mr. McGirl) and Christine M.
McGirl (Mrs. McGirl), were married to each other at all relevant
times and resided in St. Paul, Minnesota, at the time they filed
their petition.
Mrs. McGirl graduated from high school but did not attend
college. She did not take any accounting or bookkeeping courses
in high school. Before she worked at Mickey's Diner and the
Yogurt Station, both described below, Mrs. McGirl worked as a
receptionist at a doctor's office, as a secretary at various
places, and as a cashier at a grocery store.
Mr. McGirl graduated from the University of Minnesota with a
bachelor of science degree in American history and industrial
relations. He did not take any accounting or bookkeeping courses
in college or high school. Before operating Mickey's Diner and
the Yogurt Station, he worked in a warehouse and as a production
foreman trainee in a foundry.
Mickey's Diner
Mr. McGirl bought Mickey's Diner, a 24-hour diner, before he
started the Yogurt Station. Mrs. McGirl worked at Mickey's
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