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advice was in error, we note that Ms. Clark had no prior
relationship with Renaissance. On the facts of this case, we
find Mrs. Smith’s reliance on Ms. Clark was reasonable.
Accordingly, we decline to sustain respondent’s determination as
to the accuracy-related penalties.
To reflect the foregoing,
Decision will be entered for
respondent as to the deficiencies
and for petitioners as to the
accuracy-related penalties.
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Last modified: November 10, 2007