- 65 - 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.Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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