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WOODSUM v. COMMISSIONER

Docket No. 18934-09.

136 T.C. 585 (2011)

STEPHEN G. WOODSUM AND ANNE R. LOVETT, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 13, 2011.

Attorney(s) appearing for the Case

David H. Hopfenberg , for petitioners.

Patrick F. Gallagher , for respondent.

OPINION

GUSTAFSON, Judge:

This case is before the Court pursuant to section 6213(a)1 for redetermination of an accuracy-related penalty of $104,295 that the Internal Revenue Service (IRS) determined against petitioners Stephen G. Woodsum and Anne R. Lovett for tax year 2006, pursuant to section 6662(a). The issue for decision is whether petitioners had "reasonable cause" under...

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