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petitioner. Imposition of the section 6662(a) penalty in this
case is amply justified and, therefore, is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decisions will be entered under
Rule 155 in docket No. 6195-99S and
for respondent in docket No. 13337-99S.
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Last modified: May 25, 2011