Having studied all five of these taxpayer efforts to defeat the IRS’s assertion of the § 6662 accuracy-related penalty, you understand that in only two of the five cases were the taxpayers successful in that regard. In 75-100 words, compare and contrast the two “winners” against the other three and explain to me what generalized lessons you distill as to how or why taxpayers either succeed or fail in fighting the IRS on § 6662.

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