Robert D. and Carol A. Berryman - Page 12




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          petitioners here were carrying on their Melaleuca activities for            
          profit.  Accordingly, respondent’s determination that petitioners           
          are liable for accuracy-related penalties under section 6662(a)             
          is sustained.                                                               
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                                        respondent.                                   


































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