David Carkhuff and Tonja Carkhuff - Page 8

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          includes any careless, reckless, or intentional disregard.  Sec.            
          6662(c).  The deemed admissions establish that petitioners are              
          liable for the penalty with regard to the entire underpayment.              
          The deemed admissions establish that no genuine issue of material           
          fact exists as to the issue of negligence and, therefore,                   
          respondent is entitled to a decision on this issue as a matter of           
               Accordingly, respondent's Motion for Summary Judgment will             
          be granted as to all issues.                                                
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered granting             
                                        respondent's motion for summary               

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