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that they acted in good faith. Although petitioners were able to
produce some records at the administrative level and at trial
that support their entitlement to business expense deductions,
nearly all of the figures which petitioners listed on their 1992
Schedule C were erroneous. We hold that petitioners are liable
for the section 6662(a) accuracy-related penalty.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011