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because of respondent’s agent’s advice that the period for
assessment of Career’s tax for its 1992 fiscal year had expired.
The testimony of petitioners’ certified public accountant does
not support petitioners’ claim that respondent’s agent is in any
way responsible for petitioners’ being subject to the determined
penalties. Other than those assertions, petitioners have not
presented any evidence or made any other showing as to why
respondent’s penalty determinations are in error. Although a
Rule 155 computation will be necessary to determine the penalty
amounts, if any, for each petitioner, we hold that petitioners
have failed to show that respondent erred in determining any of
the section 6662(a) penalties.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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