James B. and Joan E. Murtaugh - Page 24

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          and $55 for 1992.  Thus, respondent has conceded that petitioners           
          are not liable for additions to tax in excess of the amounts in             
          the stipulation.  Further, for 1990 and 1992 petitioners have               
          conceded that with respect to the additions under section                   
          6651(a), their failure to file tax returns was not due to                   
          reasonable cause; and, with respect to the additions under                  
          section 6654, they do not qualify for any exceptions to the                 
          additions in section 6654(e).  The only remaining matters with              
          respect to additions to tax are computational, which can be                 
          addressed in the Rule 155 computation.                                      
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                           under Rule 155.                            























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