Garry D. Acuncius and Danalene L. Acuncius - Page 9

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          occurred.  We hold, therefore, that petitioners are not liable              
          for the accuracy-related penalty.                                           
               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 for petitioners.            

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