The taxpayers' appeals from gross negligence penalties were dismissed. Their income was roughly 2.5 times and 3 times what they reported, respectively, and their only explanation was an error arising from removing a column in an accounting spreadsheet. Jorré J. emphasized that "there is a world of difference" between living on the $86,000 reported by them on a combined basis and the $240,000 earned (para. 63).
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world of difference between $86K and $240K
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