Robert C. and Gail K. Racine - Page 19

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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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