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calculation of his AMT liability for 1991, or the claimed
business and other expense deductions for 1992 not allowed by
respondent. Petitioner has not established his lack of
negligence in this case with respect to these items. Sec. 6001;
Stovall v. Commissioner, 762 F.2d 891, 895 (11th Cir. 1985),
affg. T.C. Memo. 1983-450; Crocker v. Commissioner, supra at 917.
We sustain respondent's determination of the addition to tax
under section 6651(a) and the accuracy-related penalties under
section 6662(a).
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011