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provisions involved are highly complex, and the fact that his
conclusion was erroneous does not mean that petitioner’s reliance
was not reasonable. Consequently, we conclude that petitioner
has established reasonable cause for not filing the returns and,
therefore, the additions to tax under section 6651(a)(1) are
inappropriate.
Decision will be entered for
respondent with respect to the
deficiencies, and for petitioner
with respect to the additions to
tax under section 6651(a)(1).
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Last modified: May 25, 2011