John Karason - Page 19




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          burden of production, and petitioner, having failed to show                 
          reasonable cause, substantial authority, or other basis for                 
          reducing the underpayment on which the penalty is imposed, is               
          liable for the section 6662 penalty for 2001.                               
               The Court, in reaching its holding, has considered all                 
          arguments made and concludes that any arguments not mentioned               
          above are moot, irrelevant, or without merit.                               
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          




























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Last modified: November 10, 2007