- 54 - 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.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54
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