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On the basis of the record, we hold that petitioner is
liable for an accuracy-related penalty under section 6662(a) for
the 1994 tax year.
We have considered all arguments by the parties, and, to the
extent not discussed above, conclude that they are irrelevant or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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