- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011