PAUL KELLY, JR., Circuit Judge.
Taxpayer-Appellants Ronald and Cynthia Van Scoten (collectively, the "Van Scotens") appeal from the Tax Court's decision in Van Scoten v. Commissioner, T.C. Memo.2004-275, 2004 WL 2785918 (2004) ("T.C.Memo"), holding them liable for an accuracy-related penalty of $2,872 imposed by the Commissioner of Internal Revenue ("Commissioner") as a result of their negligence in claiming losses from a cattle partnership they were...
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