John A. Rowe and Donna L. Rowe - Page 65




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          interest income.  For 1990, petitioners reported business income            
          of $297,756.  Petitioner testified that she believed that her               
          wage income for 1990 was grouped in with the business income                
          reported on the return.  Petitioner further testified that she              
          believed the return was correct because it was prepared and                 
          signed by petitioners’ accountant, Mr. Danley.                              
               We find that petitioner had reasonable cause for the                   
          understatement caused by the omitted wage income and omitted                
          interest income.  Furthermore, we believe petitioner acted in               
          good faith in erroneously concluding that the wage income and               
          interest income was included in the 1990 return.  Given the                 
          extreme facts and circumstances of this case, we believe that               
          respondent abused his discretion by failing to grant petitioner             
          relief from joint liability for the accuracy-related penalty for            
          1990.  Accordingly, we hold that petitioner is not liable for               
          this penalty for 1990.                                                      
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             under Rule 155.                          














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