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his failure to include the $18,432 in his gross income. Rather,
the evidence presented in this case overwhelmingly shows that
petitioner had no reason to believe that his receipt of the
Nortel stock was anything other than a distribution taxable as an
ordinary dividend. On this record, we conclude that petitioner
is liable for the accuracy-related penalty under section 6662(a),
as determined by respondent.
Contentions we have not addressed are irrelevant, moot, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011