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Petitioner has offered no explanation or argument on this
issue. Petitioner has engaged in a lengthy and consistent
pattern of underreporting income and of claiming deductions for
losses sustained in an activity not engaged in for profit. See
Hastings v. Commissioner, supra. We therefore hold that
petitioner is liable for the section 6662(a) accuracy-related
penalty for the 1993 taxable year.
To reflect the foregoing and respondent’s concessions,
Decision will be entered
under Rule 155.
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