J. Clark and Mary R. Bundren - Page 13




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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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