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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