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Furthermore, petitioner provided his accountant with the
relevant loan documents. As reflected in the amortization
schedule prepared by petitioner’s accountant, the accountant was
aware that petitioner borrowed $25,000 from the plan the payment
of which was to be amortized over 15 years. The same accountant
prepared petitioner’s 1994 income tax return.
Based on the record before us, we find that petitioner acted
with reasonable cause and in good faith in reporting his 1994
income tax liability. Accordingly, the accuracy-related penalty
does not apply.
In reaching our holdings herein, we have considered all
arguments made by the parties, and to the extent not mentioned
above, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011