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However, the Court sustains the negligence penalty for any
underpayment for that year attributable to (1) the $88,181 of
gross receipts that respondent properly shifted from the taxable
year ended July 31, 1991, to taxable year ended July 31, 1990;
(2) depreciation deductions disallowed for the automobile and
boat; and (3) the excessive portion of the rental expense
deduction.
Based upon the stipulations and the above holdings,
Decision will be entered
under Rule 155.
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