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us, we also conclude that petitioners had no reasonable cause for
excluding from gross income the income earned by Mr. Fugitt from
Southeast. Accordingly, we sustain respondent’s determination
that petitioners are liable for the accuracy-related penalty
under section 6662(a) based on the understatement of income tax
for 1999.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011