Joyce E. and Jerome G. Beery - Page 17

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          hold that petitioners have failed in their burden of proof.  Rule           
          142(a).  We sustain respondent's disallowance of the car and                
          truck expenses, and we sustain respondent’s imposition of the               
          accuracy-related penalties under section 6662(a).                           
               Respondent filed a motion for partial summary judgment prior           
          to trial.  Because the issues raised therein have been decided in           
          this opinion, respondent's motion for partial summary judgment              
          will be denied as moot.                                                     

                                             Respondent’s motion for                  
                                        partial summary judgment will be              
                                        denied as moot, and decision will             
                                        be entered under Rule 155.                    

























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