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parties also stipulated Bailin and petitioner never discussed the
issue and that they "assumed" the litigation costs were
deductible. On this record, we conclude the elements for
reasonable reliance on a tax adviser are not satisfied. We hold
petitioner is liable for the penalty for negligence on the entire
deficiency resulting from the Rule 155 computation.
In reaching our holdings herein, we have considered each
argument made by the parties, and, to the extent not discussed
above, find those arguments to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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