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Petitioner has practiced law for many years and was aware of
the requirement that complete and accurate books and records be
maintained with respect to the financial activities of NTG.
Petitioner did not present any evidence nor did he make any
argument as to why the penalty for negligence should not apply to
the disallowed $35,000 partnership loss deduction. Although
neither petitioner nor respondent made any specific argument as
to whether the penalty for negligence should apply to the other
adjustments that have been agreed upon, those other adjustments
were settled largely in a manner favorable to petitioner. We
conclude that petitioner is liable for the penalty for negligence
only with respect to the portion of the income tax deficiency
attributable to the claimed $35,000 NTG partnership loss.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011