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insignificant figures, and we find it hard to believe that, when
preparing or supervising the preparation of the return,
petitioner would not have questioned the deduction of this size.
This is particularly true because petitioner was aware that his
Federal income taxes had been paid from the bank account used for
the accounting practice, a practice which in and of itself is
suspect. Either he closed his eyes to the facts, or he simply
did not properly supervise the preparation of the return.
Petitioner has not established that he was not negligent.
Therefore, respondent's determination as to the accuracy-related
penalty under section 6662(a) is sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011