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the $26 million loan. We reject petitioner’s arguments on this
issue.
For each of the years in issue and for each adjustment
reflected in respondent’s notice of deficiency, respondent
determined an accuracy-related penalty under section 6662(a)
against petitioner for substantial understatements of tax.
With regard to the disallowance for 1992 of the claimed
$650,000 in acquisition-related expenditures that we sustain
herein, petitioner has not demonstrated that it had substantial
authority to support this claimed deduction, and we sustain
imposition of this penalty.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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