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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined an accuracy-related penalty under
section 6662(a) of $2,900 with respect to petitioner’s Federal
income tax for the taxable year 2000.
The only issue for decision is whether petitioner is liable
under section 6662(a) for an accuracy-related penalty. We hold
that he is not.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts, supplemental stipulation of facts, and accompanying
exhibits.
At the time that the petition was filed, petitioner resided
in Buffalo, New York.
Petitioner and his former spouse were married in August
1982. They had three children from their marriage, born in
October 1983, March 1987, and June 1990.
Petitioner has been a mortgage broker for more than 20 years
and is a senior vice president at a mortgage banking company.
During their marriage, petitioner’s former spouse was a
homemaker.
At all relevant times, petitioner has maintained several
brokerage accounts, solely in his name, at First Albany Capital
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