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c. Conclusion
We conclude that petitioner did not have reasonable cause
for his underpayments of tax for 1989 and 1991. Accordingly, we
hold that petitioner is liable for a section 6662(h) accuracy-
related penalty for 1989 and a section 6662(a) accuracy-related
penalty for 1991, both in the amounts alleged by respondent in
his answer.10
We have considered all arguments made by petitioner for
holdings contrary to those expressed herein, and we conclude that
those arguments not discussed herein are either irrelevant or
without merit.
Decision will be entered
for respondent.
10 As to the amounts of these accuracy-related penalties, we
have reviewed respondent’s computations of the amounts set forth
in his answer and find them to be correct.
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