Clayton W. Plotkin - Page 14




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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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