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Next, respondent reserved hearsay objections to Exhibits
400-P, 401-P, 405-P, and 478-P. We need not address these
objections, however, because they were withdrawn by respondent in
his opening brief.
Finally, respondent reserved an objection to Exhibit 402-P
on the grounds that the exhibit is incomplete. Again, while the
incomplete nature of the document affects the weight that it is
accorded in our findings, we overrule respondent’s objection and
hold that the exhibit is admissible. See, e.g., Goichman v.
Commissioner, T.C. Memo. 1987-489 n.12.
II. Negligence
With respect to each of the years in issue, section 6653
imposes one or more additions to tax on certain underpayments
attributable to negligence or intentional disregard of rules and
regulations. With respect to petitioner’s taxable years 1978,
1979, and 1980, the addition to tax under section 6653(a) is
equal to 5 percent of the entire amount of an underpayment if any
part of the underpayment is due to negligence or intentional
disregard of rules or regulations. With respect to petitioner’s
taxable year 1981, the addition to tax under section 6653(a)(1)
is the same as that imposed under the former section 6653(a).
However, with respect to that year, section 6653(a)(2) provides
for a further addition to tax equal to 50 percent of the interest
due on only that portion of the underpayment that is attributable
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