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sue is a question of fact. In Reser, two C.P.A.’s from a
national accounting firm (one of whom testified at trial) agreed
that the taxpayers were entitled to the deduction they claimed.
See id. at 1271. In contrast, petitioners’ C.P.A. did not
testify in this case.
We conclude that petitioners are liable for the section 6662
penalty. To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011