Bill J. Malone, Jr. and Sarah J. Malone - Page 15

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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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