Antonio T. Croteau - Page 13

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          proper tax liability and the knowledge and experience of the                
          taxpayer.  Sec. 1.6664-4(b)(1), Income Tax Regs.                            
               Petitioner makes no argument concerning respondent's deter-            
          mination under section 6662(a) except for his claim, which we               
          have rejected, that he and Ms. Croteau did not intend that the              
          terms of the agreement control the payments at issue.  Based on             
          our examination of the entire record before us, we find that                
          petitioner has failed to show that he acted with reasonable cause           
          and in good faith, or that he otherwise exercised due care or               
          made a reasonable attempt to comply with the Internal Revenue               
          Code, when he claimed the alimony deduction at issue.  Accord-              
          ingly, we sustain respondent's determination imposing the                   
          accuracy-related penalty under section 6662(a) for 1993.                    
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        for respondent.                               

















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