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The court mentioned that this confirmed a lack of excellent religion in tax reporting and, on that basis, it concluded that the McNultys didn't act fairly or in good religion. The McNultys also argued that no penalties should apply because they acted with cheap cause and in good faith beneath Code Sec. Alternatively, they argued that an exception to the custodial requirement applied below Code Sec. The McNultys argued that the AE coins had been belongings of Inexperienced Hill and that Donna's bodily receipt of them didn't represent taxable distributions from her IRA.<br>