Investment Research Associates - Page 567




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          Issue 41.  Whether IRA Is Liable for the Section 6662(a)                     
          Accuracy-Related Penalty for 1989                                            
                                       OPINION                                         
               In the notice of deficiency for 1989, respondent determined             
          that IRA was liable for an accuracy-related penalty of $175,780              
          due to negligence or disregard of rules or regulations and a                 
          substantial understatement of tax.  IRA had the burden of proving            
          that the imposition of the accuracy-related penalty was                      
          erroneous.  It failed to do so.  Therefore, we sustain                       
          respondent's determination.                                                  
          Conclusion                                                                   
               To reflect our disposition of the issues in controversy and             
          those settled or conceded by the parties,                                    


                                                   Decisions in all dockets            
                                              will be entered under Rule               
                                              155.                                     



















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