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law that is reasonable in light of the experience, knowledge, and
education of the taxpayer may indicate reasonable cause and good
faith. Remy v. Commissioner, T.C. Memo. 1997-72.
The facts of this case do not support petitioner. She
sponsored an activity for the purpose of generating income, and
in which she was quite successful. There is little argument, if
any, that can be made for petitioners’ exoneration of this
penalty, nor have petitioners advanced any argument. Respondent
is sustained on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011