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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
underpayment.
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
Division.
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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Last modified: May 25, 2011