Michael W. Allen - Page 14

          understatement for each of the years at issue was due to                    
          reasonable cause and that he acted in good faith.10                         
               Accordingly, we sustain respondent’s determination that                
          petitioner is liable for the accuracy-related penalty under                 
          section 6662(b)(2) for each of the years at issue.                          
               We have considered all remaining arguments the parties made            
          and, to the extent not addressed, we find them to be irrelevant,            
          moot, or meritless.                                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

               10Petitioner argues that the complexity of issues in this              
          case gave him reasonable cause for his substantial                          
          understatements.  See Dillin v. Commissioner, 56 T.C. 228, 248              
          (1971).  We disagree.  There is no uncertainty as to petitioner’s           
          legal obligation here.  See, e.g., Pessin v. Commissioner, 59               
          T.C. 473, 489 (1972); Rosanova v. Commissioner, T.C. Memo. 1985-            
          306; Grant v. Commissioner, T.C. Memo. 1980-242.                            

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