Stephen Neal Swihart - Page 9

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               As to the underpayment due to the additional tax under                 
          section 72(t), because of matters discussed above, we find that             
          petitioner acted with reasonable cause and good faith.                      
               Accordingly, petitioner is not liable for the accuracy-                
          related penalty as provided by section 6662(a).                             


                                             Decision will be entered                 
                                        under Rule 155.                               
































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