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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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