Steven M. and Karen Arhontes - Page 14




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          regulations with regard to the adjustments in the notice of                 
          deficiency that were sustained by this Court.  Accordingly, the             
          accuracy-related penalty under section 6662(a) is sustained.                
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   



                                             Decision will be entered                 
                                        under Rule 155.                               
































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