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at trial or on brief and has failed to propose any findings of
fact that would lead to the conclusion that any of the exceptions
found in section 6654(e) applies to petitioner. Petitioner has
failed to prove facts to contradict respondent’s determination of
an addition to tax in the amount of $1,029.42 under section
6654(a). Therefore, we sustain respondent's determination of an
addition to tax under section 6654(a), subject only to
recalculation of the deficiency.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011