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the sale of her interest in the Happy Valley property on her
Federal income tax returns for 1997 and 1998. We also hold that
respondent’s determination to impose accuracy-related penalties
under section 6662(a) was warranted due to petitioner’s
negligence or disregard of the rules or regulations or,
alternatively, to a substantial understatement of income tax. We
have considered the arguments of the parties not specifically
addressed in this opinion. Those arguments are either without
merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
for respondent.
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