Robert J. Sugarman - Page 14

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          petitioner intended to abandon the issue, but in any case                   
          respondent's determination of the applicable penalty must be                
          sustained with respect to the underpayment for the improper                 
          interest deduction as petitioner has not met his burden of proof            
          on this matter.                                                             
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               
































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