-13- sufficient knowledge to understand, and in fact knew, the benefits flowing to them by Mr. Arthur’s acts. They could have objected to the writeoff but either affirmatively acquiesced in it or purposely chose to be silent. Accordingly, we conclude that petitioners had no reasonable cause for omitting income realized from the discharge of indebtedness. We therefore hold that the underpayment of tax was due to petitioners’ negligence and disregard of rules or regulations. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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