Robert P. and Christine M. Lolli - Page 7

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               Petitioners failed to offer any evidence regarding                     
          respondent's determination of an accuracy-related penalty in this           
          matter.  Accordingly, they have not met their burden of proof,              
          and respondent's determination will be sustained.                           
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             under Rule 155.                          



































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