- 4 -
and copious citation of precedent"; if we did, it might suggest
they had some merit. Crain v. Commissioner, 737 F.2d 1417 (5th
Cir. 1984).
Petitioner did not introduce any evidence to show that he is
not liable for the income tax deficiencies and accuracy-related
penalties under section 6662(a); accordingly, respondent is
sustained on these issues for all 3 years.
Decisions will be
entered for respondent.
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Last modified: May 25, 2011