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106 LTD. v. COMMISSIONER

Docket No. 14586-05.

136 T.C. 67 (2011)

106 LTD., DAVID PALMLUND, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 10, 2011.

Attorney(s) appearing for the Case

William A. Roberts and Kyle R. Coleman, for petitioner.

Nancy B. Herbert, Richard Hassebrock, and Jadie T. Woods, for respondent.

HOLMES, Judge:

David Palmlund bought into a bad deal to lose money but save on taxes. He has since filed an amended return and paid the tax he was trying to avoid. But he contests the penalty that the Commissioner asserts against him; he argues that he relied in good faith on professional advisers.

FINDINGS OF FACT

I. Palmlund

David Palmlund started his professional life in upstate...

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