Oliver K. Robinson and Deborah L. Robinson, et al. - Page 27




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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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