Hubert R. G. Raney - Page 7




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          additions to tax, nor did he address this issue in his brief.  We           
          therefore uphold respondent’s determination on this issue.                  


                                                  Decision will be entered            
                                             for respondent with respect              
                                             to the deficiencies and the              
                                             additions to tax under section           
                                             6654(a) and for petitioner               
                                             with respect to the additions            
                                             to tax under section 6651(f).            































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