- 6 -
sustain respondent’s determination of the addition to tax under
section 6661.
Prior to submission of this case for decision, petitioner
filed a motion for partial summary judgment. Because the issues
raised therein have been decided in this opinion, petitioner’s
motion for partial summary judgment will be denied as moot.
To reflect the foregoing,
Petitioner’s motion for
partial summary judgment will
be denied as moot, and
decision will be entered for
respondent.
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Last modified: May 25, 2011