Joel Baker - Page 13

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          expenses paid to A & S were sufficiently related to his                     
          employment to warrant a deduction.  Therefore, we conclude that             
          the accuracy-related penalty is not applicable to the portion of            
          the underpayment attributable to this adjustment.                           
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             under Rule 155.                          


































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