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believe petitioners have not proved this. There is no evidence
that petitioners gave Sawyer information showing that
petitioner’s FabuGlass stock qualified under section 1244, i.e.,
information showing that FabuGlass derived more than 50 percent
of its aggregate gross receipts from sources other than
royalties, rents, dividends, interest, annuities, and sales or
exchanges of stocks or securities for 1990-94, that its
deductions exceeded its income for 1990-94, or that it was
largely an operating company in 1990-94. Thus, we conclude that
petitioners are liable for the accuracy-related penalty for 1995.
To reflect the foregoing,
Decision will be
entered for respondent.
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