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return, or $5,000. Sec. 6662(d)(1)(A). Petitioner has presented
no argument on this issue other than to deny the underlying
deficiencies. Because the understatements at issue are
substantial and neither is subject to reduction pursuant to
section 6662(d)(2)(B)(i), section 6662(d)(2)(B)(ii), or section
6664(c)(1), respondent's determination is sustained.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011