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and we note that revenue rulings are not ordinarily precedential
in this Court. Gordon v. Commissioner, 88 T.C. 630, 635 (1987).
Based on the foregoing, we hold that section 6653(a)(2)
applies to the full amount of the deficiency agreed upon by the
parties.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011