Jimie R. and Sandra Herlitschek Overby - Page 9

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          reasonable cause and that they acted in good faith.  Accordingly,           
          we hold petitioners are liable for the accuracy-related penalty.            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                             for respondent.                          


































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