Mark and Helen Thomson - Page 10




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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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