OPINION
BOYCE F. MARTIN, JR., Circuit Judge.
This is an appeal from the United States Tax Court's decision upholding the Commissioner's determination that Mr. Mortensen is liable for a section 6662(a) negligence penalty of $784 for the taxable year 1991. The penalty stems from Mortensen's deductions on his tax return based on his investment in cattle breeding partnerships established by Walter J. Hoyt III. The Hoyt Partnerships have generated litigation...
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