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referred us to nor have we found any cases that have previously
answered the question before us. Accordingly, in light of all
the facts and circumstances, we find petitioners acted reasonably
and in good faith with respect to the underpayment for 2002 and
are not liable for the accuracy-related penalty under section
6662(a).
We have considered the other arguments of the parties and,
to the extent not discussed, we conclude that the arguments are
irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
for respondent with respect to
the deficiency and for
petitioners with respect to
the penalty under section
6662(a).
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Last modified: May 25, 2011