Robert Louis Rusten and Suzan Veronica Rusten, Deceased, Kelly Farrier, Personal Representative - Page 10




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               Under section 6662(d)(2)(B)(i), the amount of a tax                    
          understatement may be reduced by the portion thereof that is                
          attributable to the tax treatment of an item for which there was            
          substantial authority.  We find that given the unusual                      
          circumstances of this case, petitioners’ underreporting of Mr.              
          Rusten’s self-employment tax was due to reasonable cause.                   
          Therefore, the penalty under section 6662 is not applicable.                
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          




























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Last modified: March 27, 2008