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believe that he did not realize income from his canceled debt and
that he acted in good faith. Accordingly, we hold that
petitioner is not liable for the accuracy-related penalty.
Conclusion
We have considered all of the other arguments made by the
parties, and, to the extent that we have not specifically
addressed them, we conclude that they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues,
Decision will be entered
for respondent as to the
deficiency in tax and for
petitioner as to the penalty.
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Last modified: May 25, 2011