25% of $877,300 is $219,325. The decision seems crazy to me. The purpose of the penalty is supposed to be to protect the government. The government lost NOTHING in this case. I sure hope the decision is appealed, because it's a lousy one. And to go back to my topic heading, I find it outrageous that the IRS even applied the penalty in the first case, given the specific details. This is sheer extortion by force by our government.