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her proper tax liability, including an honest misunderstanding of
fact or law that is reasonable in light of all of the facts and
circumstances. Id.
Petitioner intended and calculated that the $35,000 payment
made to Tulay was rehabilitative alimony for her to obtain a
postgraduate degree. Looking to all of the facts and
circumstances, it was reasonable for petitioner to believe that
the $35,000 payment to Tulay was deductible alimony, and we
conclude that he acted in good faith.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiency and for petitioner
as to the penalty.
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