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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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