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of Mr. Cordes as repossession costs. Mr. Hinman was the
only member of petitioner's firm of outside certified
public accountants to testify at trial. Moreover, none of
petitioner's employees who testified at trial attributed
the errors in petitioner's return to advice received from
its accountants. Therefore, we reject petitioner's
contention that it acted with reasonable cause and in good
faith.
We also reject petitioner's contention that the
accuracy-related penalty should not be imposed because
there was no underpayment. As discussed above in
connection with the fraud penalty, petitioner cites no
authority for its contention that the underpayment in this
case must be determined "exclusive of the accounting change
issue". The definition of underpayment contained in
section 6664(a) and the regulations promulgated thereunder,
section 1.6664-2(a), Income Tax Regs., requires otherwise.
In light of the foregoing and concessions by the
parties,
Decision will be entered
under Rule 155.
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