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judgment. Walters was intimately involved with petitioners’
financial dealings, including the exchange. He attended the
closing of the exchange and reviewed the documents. Accordingly,
he was in possession of necessary and relevant information
regarding the exchange. Clearly, petitioners relied on Walters’
judgment with regard to these matters. On the basis of all the
evidence in the record, taking into account the relative
complexity of the tax issues involved and petitioners’ lack of
experience or training in such matters, we find that petitioners’
reliance was reasonable and in good faith. We conclude that the
accuracy-related penalty should not be imposed. See Coblenz v.
Commissioner, T.C. Memo. 2000-131; Sather v. Commissioner, supra.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011