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Pelton & Gunther v. Commissioner, T.C. Memo. 1999-339; Estate of
Holland v. Commissioner, T.C. Memo. 1997-302, but as best can be
determined from the record, petitioner’s professional experiences
relate to matters other than Federal income taxation.
We noted from the outset that placing ownership of a
business conducted through an unincorporated association was not
easy, and we expect that reasonable minds could differ as to the
foregoing analysis and conclusion on the point. We are not
persuaded that petitioners did not have sufficient reasonable
cause to avoid the imposition of the penalty for each year, and
we so find. Accordingly, petitioners are not liable for a
section 6662(a) penalty for either year in issue.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011