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forward with evidence sufficient to persuade the Court that
respondent’s determination is incorrect. See Rule 142(a); Welch
v. Helvering, 290 U.S. at 115; see Higbee v. Commissioner, supra
at 447.
We hold that petitioner is liable for the addition to tax
pursuant to section 6654(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011