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the extent of the taxpayer’s efforts to assess his or her proper
tax liability. See id.
Petitioners presented no evidence and make no argument
regarding the accuracy-related penalties determined by respondent
for 1993 and 1994. On the record before us, we sustain respon-
dent’s determinations that petitioners are liable for each of the
years 1993 and 1994 for the accuracy-related penalty with respect
to their underpayment of tax for each of those years.
To reflect the foregoing and the concessions of the parties,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011