Stephen G. Woodsum and Anne R. Lovett v. Commissioner

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 section 6664(c)(1) for omitting $3.4 million of income from their joint 2006 Federal income tax return.

Background

The parties submitted this case fully stipulated, pursuant to Rule 122. We incorporate by this reference…