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for the accuracy-related penalty under section 6662 for
underpayments attributable to negligence or disregard of rules or
regulations.
In reaching our decision, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
irrelevant, moot, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008