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background and reliance, we hold that his actions with respect to
that item were reasonable and are not subject to the section 6662
penalty.
With respect to the substantiation items and any items
conceded, petitioner has failed to show that his actions were
reasonable and not careless, reckless, or made with intentional
disregard of rules or regulations. Even considering petitioner’s
background, his inability to substantiate claimed expenditures is
not reasonable. Under these circumstances, we hold that
petitioner is liable, in each of the 3 taxable years, for the
accuracy-related penalty under section 6662(a) on the portion of
any underpayment attributable to the substantiation issues
decided and on the adjustment items that he conceded.
To reflect the foregoing and due to concessions,
Decision will be entered under
Rule 155.
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