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Commissioner, T.C. Memo. 1989-568. We disagree with petitioners
that they had any such misunderstanding of fact sufficient to be
a defense to the accuracy-related penalty under section 6662(h).
In addition to the fact that the record is devoid of any evidence
establishing that petitioners relied on Bales in investing in
TBS 90-1 and claiming the purported loss for 1992 flowing
therefrom, the case of Bales involved different participants,
different partnerships, and different years. See Hansen v.
Commissioner, 471 F.3d at 1032-1033; Mortensen v. Commissioner,
440 F.3d 375, 391-392 (6th Cir. 2006), affg. T.C. Memo. 2004-279;
Sanders v. Commissioner, T.C. Memo. 2005-163.
5. Conclusion
We conclude that petitioners are liable for the section
6662(h) accuracy-related penalty for 1992, as determined by
respondent. See McDonough v. Commissioner, T.C. Memo. 2007-101.
We have considered all arguments made by petitioners for a
contrary holding, and we conclude that any argument not discussed
herein is either irrelevant or without merit.
An appropriate order and
decision will be entered.
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Last modified: November 10, 2007