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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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Last modified: May 25, 2011