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The Court finds that respondent has met his burden of
production and that petitioners were negligent. Petitioners did
not properly substantiate their deductions as required by the IRC
and the regulations. Petitioners did not establish a defense for
their noncompliance with the IRC’s requirements. Accordingly,
respondent’s determination is sustained.
To reflect the foregoing,
An order of dismissal will be
entered as to petitioner Amy K.
Moore, and decision will be entered
for respondent.
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Last modified: March 27, 2008