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Although petitioner disputed the section 6662(a) accuracy-
related penalty in his petition, petitioner has made no arguments
under section 6662(d)(2)(B) or 6664(c)(1) against imposition of
the penalty. Indeed, when provided the opportunity at trial to
address the penalty, petitioner responded: “I haven’t been that
concerned about it, so I guess the short answer is no, I have
nothing.” We conclude, therefore, that petitioner is liable for
a section 6662(a) accuracy-related penalty for substantial
understatement of tax.
We have considered the remaining arguments of both parties
for results contrary to those discussed herein and, to the extent
not discussed above, find those arguments to be irrelevant, moot,
or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011