- 21 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Last modified: May 25, 2011