Edward C. and Susan R. Hanna - Page 17

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          professional, they do establish that petitioners made an honest             
          effort to comply with the substantiation requirements and assess            
          their proper tax liability.  Petitioners have shown reasonable              
          cause for the underpayment and demonstrated that they were                  
          acting in good faith.  Accordingly, we conclude that petitioners            
          are not liable for the accuracy-related penalty under section               
          6662(a).                                                                    
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              

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




















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