- 33 -
Decision was entered in that case on April 5, 2000, and affirmed
early in 2002. Thus, when they filed their 1995 return,
petitioners knew that respondent had allowed them to claim
similar deductions for 1991-93, and they knew their 1994 return
was being audited; but they did not know they would not prevail
on this issue for 1994. Under these circumstances, we conclude
that petitioners had a reasonable basis for claiming the
deductions that respondent disallowed, and that petitioners
believed in good faith that they could deduct the $15,000 for
tuition and Mishna payments on their 1995 return.
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
[Reporter’s Note: This Opinion was amended by Order dated February
6, 2006.]
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