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Based on our examination of the entire record before us, we
find that petitioner has failed to establish error in respon-
dent’s determination that it is liable for the year at issue for
the accuracy-related penalty under section 6662(a). Conse-
quently, we sustain that determination.
To reflect the foregoing and the concession of respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011