Lee D. Froehlich - Page 33

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               We hold petitioner was reasonable in his reliance on                   
          advisers and in his reporting position, and, accordingly, he is             
          not liable for the accuracy-related penalty under section 6662(a)           
          for the 1990 taxable year.                                                  
               To reflect the foregoing and due to concessions,                       
                                             Decision will be entered                 
                                        under Rule 155.                               

































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Last modified: May 25, 2011