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At her employer's annual holiday party, Maddie won as part of a grand prize drawing a vintage 1967 Chevrolet Camaro. Although it was announced

At her employer's annual holiday party, Maddie won as part of a grand prize drawing a vintage 1967 Chevrolet Camaro. Although it was announced at the party that the car had a value of $35,000, the 1099-MISC information return that Maddie received from her employer showed the value of the Camaro at $1,000. Maddie had her return prepared by a paid tax preparer, Mr. Price. At the time Maddie showed the 1099-MISC to Mr. Price, Maddie explained that she had won the car at a company party, but she did not explain that the actual fair market value of the car was $35,000. Mr. Price did not inquire about the value of the car. Instead, he reported $1,000 of income on Maddie's return, reflecting the receipt of the car. Assume that Maddie's failure to report $35,000 of income from winning the car (rather than just $1,000) resulted in an $8,000 tax understatement and a corresponding underpayment of the same amount. Assuming the IRS can establish that the Camaro's actual fair market value on the date of the drawing was $35,000, may the IRS impose an accuracy-related penalty with respect to Maddie's return?

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