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production for his determination of the accuracy-related penalty
based on negligence or disregard of rules or regulations.
Additionally, with regard to that determination, petitioners have
failed to meet their burden of proving that they acted with
reasonable cause and in good faith. We therefore sustain
respondent’s determination that petitioners are liable for the
accuracy-related penalty on the underpayment associated with the
disallowed itemized deductions conceded by petitioners.9
In reaching our holdings herein, we have considered all
arguments made, and to the extent not mentioned above, we find
them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
9 Because of respondent’s concessions (see supra p. 4), we
conclude that the accuracy-related penalty based on a substantial
understatement of tax is not applicable as the understatement
does not exceed the greater of 10 percent of tax required to be
shown on the return or $5,000. See sec. 6662(d)(1).
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