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purchases by $101,763, and overstated their fuel tax credit by
$8,884 for 1994. We conclude that petitioners negligently
disregarded the tax laws, and that they are liable for the
accuracy-related penalty for negligence under section 6662(a) for
1994.
C. Section 481
Petitioners contend that they are entitled to a section 481
adjustment. Respondent did not respond to petitioners’ section
481 argument in posttrial brief. We agree that section 481
applies because respondent’s adjustments sustained herein alter
the timing of certain of petitioners’ deductions, contrary to
petitioners’ traditional treatment of these items. Therefore,
the parties shall apply section 481 in connection with the Rule
155 computation.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011