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Petitioners failed to establish that they had reasonable
cause or acted in good faith in failing to maintain records for,
and failing to substantiate, Schedule C expenses for the years in
issue or for understating their gross receipts for 1995.
Accordingly, petitioners are liable for the section 6662(a)
penalty for 1995, 1996, 1997, and 1998.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011