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for a section 6662 accuracy-related penalty with respect to the
flow-through items from HGTG’s bankruptcy. With respect to the
other items on which respondent asserted on brief that petitioner
was liable for the penalty, petitioner has not provided a defense
and accordingly has not shown respondent’s determination on that
issue is in error.
To reflect the foregoing,
Decision will be entered under
Rule 155.
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