Robert G. and Lana L. Gale - Page 11

                                       - 10 -                                         
          Petitioners reasonably relied on Ms. Young.  Consequently, we               
          hold that petitioners are not liable for the section 6662(a)                
          accuracy-related penalty.                                                   
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent with respect to           
                                             the deficiency and for                   
                                             petitioners with respect to              
                                             the section 6662(a) accuracy-            
                                             related penalty.                         




























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