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therefore, failed to satisfy their burden of proof to absolve
them of liability under section 6651(a)(1). Rule 142(a); United
States v. Boyle, 469 U.S. 241, 245 (1985). Respondent,
therefore, is sustained on the addition to tax under section
6651(a)(1).
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011