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result in “impermissible stacking”. Zaban v. Commissioner, T.C.
Memo. 1997-479. Because petitioner is liable for the fraud
penalty on the entire underpayment, Mrs. Said is not liable for
the accuracy-related penalty.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011