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that, with some assiduous efforts, petitioners could have re-
sorted the records at least into their original state.
We are unmoved by petitioner’s explanation that he trusted
his father and signed anything that Jack put in front of him.
Although petitioner lacks higher education, we believe that he
was aware of his responsibility to report his income accurately.
He did not do so.
Accordingly, we conclude that petitioners’ underpayments are
attributable to negligence or disregard of rules or regulations.
Thus, we hold that petitioners are liable for accuracy-related
penalties under section 6662(a) for 1993 and 1995, based on the
amount of their underpayments for those years, to be determined
in the Rule 155 computations.
To reflect the foregoing and the parties’ concessions,
Decision will be entered
under Rule 155.
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