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case law in contending that petitioner's employment with Motorola
was temporary. On the basis of the record, we hold that
petitioners did not comply with the requirements of section
162(a)(2) and are therefore liable for the accuracy-related
penalty on the underpayment for the 1994 tax year.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011