Estate of Carolyn W. Holland, Deceased, Jack K. Holland, Lewis G. Holland, Sr., and Betty H. Kann, Executors - Page 61

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          Petitioner bears the burden of proving that respondent's                    
          determinations are erroneous.  Rule 142(a).                                 
               We find that petitioner was negligent with respect to the              
          positions it took on each of these items.  Jack is an attorney              
          whose practice includes estate planning and general tax services;           
          therefore, he either knew or should have known that the claimed             
          items are not allowable.                                                    
               Section 6664(c) provides that no penalty shall be imposed              
          under section 6662 with respect to any portion of an underpayment           

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