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returns are reasonably explained by the factually oriented
nature of each of the issues in this case, by the factually
complicated nature of the many business, investment, and
personal activities in which petitioners were involved, by the
consuming manner in which petitioners undertook each of the
activities in which they became involved, by the nature and
volume of the many categories of expenses incurred by
petitioners each year, by the nature of the books and records
which petitioners innocently but amateurishly developed and
used, by the failure of petitioners’ accountants and tax return
preparers to prepare diligently the returns in question, and by
the unfortunate relationship that developed between petitioners'
and respondent's representatives throughout the course of this
dispute.
No one of the above factors is determinative. But we
believe that, on the unique facts and circumstances of this
case, imposition of any of the asserted additions to tax would
be inappropriate. We so hold.
Decision will be
entered under Rule 155.
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