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the greater of "10 percent of the tax required to be shown
on the return for the taxable year, or * * * $5,000."
Petitioners' answering brief addresses the penalties
under section 6662(a) determined by respondent in the
following sentence:
Finally, if the Court rules in favor of the
Respondent, the Petitioners request that the
Court waive penalties and interest associated
with the understatement of income as the
Petitioners filed their tax forms in good faith,
reasonably relying on the managing partner and
the partnership bookkeeper's expertise to file
a complete and accurate tax return for the
partnership.
This Court has jurisdiction over interest determinations
to the limited extent provided by section 7481(c), which
is not applicable here. Nor does section 6404(i) apply in
the absence of a determination by respondent not to abate
interest. See Melin v. Commissioner, 54 F.3d 432 (7th Cir.
1995). Therefore, we shall not consider petitioners'
request that this Court "waive" the "interest associated
with the understatement."
We interpret petitioners' request that this Court
"waive penalties * * * associated with the understatement"
as an assertion that they qualify to be relieved of
liability for the subject penalties under the reasonable
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