-14-
record does not establish such a finding, and respondent does not
even include this assertion in his brief as a proposed finding of
fact. On the basis of section 6664(c), we hold for petitioners
as to the accuracy-related penalty.
All arguments made by the parties have been considered, and
those arguments not discussed herein have been found to be
without merit. Accordingly,
Decision will be entered
for respondent as to the
deficiency and for petitioners
as to the accuracy-related
penalty.
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Last modified: May 25, 2011