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reckless, or in intentional disregard of rules or regulations.
See sec. 6662(c); see also Rule 142(a); Welch v. Helvering, supra
at 115. Petitioner has failed to do so; thus, we sustain
respondent.
For the foregoing reasons,
Decision will be entered
for respondent.
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Last modified: May 25, 2011