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evidence that he had reasonable cause for the understatements or
that he acted in good faith. Accordingly, we sustain
respondent’s determinations.7
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect respondent’s concession,
Decision will be entered
under Rule 155.
7 Considering the amount of unreported income, respondent
has satisfied the burden of production with regard to the
penalties. See sec. 7491(c).
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Last modified: May 25, 2011