Roderick E. Carlson and Jeanette S. Carlson - Page 39




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          find that petitioners have failed to establish any error in                 
          respondent’s determination that they are liable for the year at             
          issue for the accuracy-related penalty under section 6662(a)                
          insofar as it relates to the underpayment of tax attributable to            
          petitioners’ capital gain.  Consequently, we sustain that deter-            
          mination to that extent.                                                    
               We have considered all of the contentions and arguments of             
          petitioners that are not discussed herein, and we find them to be           
          without merit and/or irrelevant.                                            
               To reflect the foregoing and the concessions of the parties,           
                                             Decision will be entered under           
                                        Rule 155.                                     



























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