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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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