Ronald L. DeVault - Page 16

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          meetings wherein he was consistently reelected to serve on the              
          board of directors until the next annual meeting.                           
               In light of petitioner’s lack of business acumen and the               
          circumstances of this case, we find that petitioner had                     
          reasonable cause to believe that he did not have an interest in             
          Union Machine in 2000 and acted in good faith with respect to the           
               Accordingly, we hold that petitioner is not liable for the             
          accuracy-related penalty under section 6662(a).                             
               C.  Conclusion                                                         
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent with respect to           
                                             the deficiency and for                   
                                             petitioner with respect to the           
                                             penalty under section 6662(a).           

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