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that any increase in the self-employment tax causes a
corresponding increase in the deduction for taxes paid on self-
employment income. Sec. 164(f).
Additions to Tax
Respondent determined that petitioners were negligent or
intentionally disregarded the rules or regulations in filing
their 1988 Federal income tax return under section 6653(a) and
their 1989 through 1991 Federal income tax returns under section
6662. Petitioners do not deny that they were negligent or
intentionally disregarded the rules or regulations, but instead
insist that there was no deficiency. Petitioners offered no
evidence which would disprove respondent's determination to the
extent we have sustained respondent herein. To the extent of the
deficiencies decided by this opinion, the additions to tax and
penalties for the tax years will apply.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011