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consideration all of the facts and circumstances contained in
this record, we conclude that petitioner acted in good faith and
that her reliance on Mr. Falcon as executor of her stepmother’s
estate was not unreasonable. The negligence penalty therefore
should not be imposed in this case.
To reflect the forgoing,
Decision will be entered
for respondent as to the
deficiency and for petitioners
as to the accuracy-related
penalty under section 6662(a).
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Last modified: November 10, 2007