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there was a reasonable cause for such portion and that the
taxpayer acted in good faith with respect to such portion. This
determination is based on all of the facts and circumstances.
Sec. 1.6664-4(b)(1), Income Tax Regs.
On the record before us, we find that there was reasonable
cause for petitioners to take the position they did and that they
acted in good faith with respect to that position. Accordingly,
we find that the penalties under section 6662(a) should not be
imposed with respect to the years in issue.
We have considered all arguments made by the parties and to
the extent not discussed above, we find these arguments to be
without merit or irrelevant.
Decision will be entered
for respondent as to the
deficiencies and for
petitioners as to the
accuracy-related penalties.
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Last modified: May 25, 2011