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we found were paid during that year with respect to the horse-
training activities. We further hold that the underpayment for
1995 for purposes of section 6662(a) must be reduced to reflect
that holding.
On the record before us, we find that, except to the extent
stated above, petitioner has failed to establish that he is not
liable for the accuracy-related penalty under section 6662(a) for
each of the years 1994 and 1995. Accordingly, except to that
extent, we sustain respondent’s determinations that petitioner is
liable for the accuracy-related penalty for each of those
years.14
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of respondent,
Decision will be entered under
Rule 155.
14Because certain of our holdings increase self-employment
income for each of the years at issue, correlative adjustments
must be made to self-employment tax for each such year. See
supra note 5.
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