Morales v. Comr., T.C. Memo. 2012-341

(petitioners, married couple, filed separate returns for separate principal residences on same tax lot with each claiming an $8,000 first-time homebuyer tax credit; however, new homes purchased within three years of selling prior principal residence; petitioners' claim that Turbo Tax software allowed the credit, but no evidence presented that result from Turbo Tax instructional error or error in programming; use of Turbo Tax not defense to accuracy-related penalty; court noted, however, that "We leave for another day whether reliance on tax preparation software such as Turbo Tax is sufficient to avoid the accuracy-related penalty where the taxpayer has provided evidence demonstrating a programming flaw or an instructional error").