- 19 - We find, therefore, that petitioners have met the burden of reasonable cause and acted in good faith when they excluded their gains. Conclusion After careful consideration of the facts and circumstances of this case, we sustain respondent’s deficiency determination but find that petitioners are not liable for the accuracy-related penalty under section 6662(a). To reflect the foregoing, Order and decision will be entered for respondent as to the deficiency but for petitioners as to the penalty.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011