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tax liability for 1986.12 Under these circumstances, petitioner
cannot insulate himself from the negligent omission of $4 million
of taxable income from the return. Accordingly, we hold that
petitioner is liable for the additions to tax for negligence for
1986.
Decision will be entered
under Rule 155.
12The $2 million difference is attributable to the fact that
petitioner’s adjusted gross income and tax liability shown on the
original return was underreported by approximately 40 percent.
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