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order are deductible by Edward, there is no substantial under-
statement of tax in the taxable years 1989 and 1990. Accord-
ingly, we hold that Edward is not liable for the penalty under
section 6662 in 1989 and 1990.
To reflect the above holdings and concessions,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011