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As such, we find that petitioners failed to make any
reasonable attempt to comply with the tax laws and carelessly
disregarded rules and regulations relating to the proper
reporting of items and record keeping. Accordingly, we sustain
respondent’s determination and hold that petitioners are liable
for the section 6662(a) accuracy-related penalty for the 1991 and
1992 tax years.
We have considered all other arguments of the parties, and
to the extent not addressed herein, we find them to be either
meritless or irrelevant.
To reflect the foregoing and concessions of the parties,
Decision will be entered
under Rule 155.
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