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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.
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Last modified: May 25, 2011