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Petitioner made no argument that he is not liable for the
accuracy-related penalty. We treat this as a concession by
petitioner. Rothstein v. Commissioner, supra; Reaves v.
Commissioner, supra. We conclude that petitioner is liable for
the accuracy-related penalty for 1989 under section 6662(a) for
negligence or intentional disregard of the rules or regulations
and that all of the deficiency is due to negligence.
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011