Polly M. Cherry - Page 21

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          Wilson.  Petitioner testified to her support of the children and            
          went to great lengths to show that they, in fact, lived with her            
          during 1993 and 1994.  Although petitioner failed to satisfy her            
          burden of proof as to how much support she provided the children            
          in relation to their total support they received, given that she            
          has no technical training in the tax law we think her failure was           
          due to an honest misunderstanding of the law.  Consequently, to             
          the extent the understatement of tax was based on such claimed              
          exemptions, we hold that petitioner is not liable for the                   
          accuracy-related penalty pursuant to sec. 6662(a).                          
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          
























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