Lawrence G. Williams - Page 15

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          one not previously considered by the Court and the statutory                
          language was not entirely clear.”).                                         
               We agree with petitioner that he made a reasonable attempt             
          to comply with the Internal Revenue Code.  Because this is a case           
          of first impression, there was no clear authority to guide                  
          petitioner as to the complex and overlapping issues of tax and              
          bankruptcy law.  We note that respondent has not referred us to             
          nor have we found any cases that have previously answered the               
          questions before us.  Petitioner had an honest misunderstanding             
          of the law, and the position petitioner took was reasonably                 
          debatable.  Accordingly, in light of all the facts and                      
          circumstances, we find petitioner acted reasonably and in good              
          faith with respect to the underpayment for the years at issue and           
          is not liable for the accuracy-related penalties under section              
          6662(a).                                                                    
               We have considered the other arguments of the parties and,             
          to the extent not discussed above, we conclude that the arguments           
          are irrelevant, moot, or meritless.                                         
               To reflect the foregoing,                                              

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









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