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return preparer testified that information revealed during the
audit of the tax liability for 1990 would have changed his
calculations as shown on the return. We therefore sustain
respondent's determination of the accuracy-related penalty as to
the entire deficiency for negligence or intentional disregard of
rules and regulations. Therefore, we need not determine whether
there is a substantial understatement of income tax. However,
this fact will be shown when petitioner's tax liability is
recomputed. If there is a substantial understatement of tax,
that fact likewise supports respondent's determination of the
accuracy-related penalty.
Decision will be entered
under Rule 155.
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