This case is before us for a second time. On the first appeal, we reversed the Tax Court's determination that a 5% penalty for negligence and intentional disregard of regulations should be assessed against this petitioner under I.R.C. § 6653(a). (C.T. p. 51.) We then affirmed the Tax Court's finding of a deficiency of $471.78 in taxes paid by appellant for the calendar year 1964.
The Tax Court vacated...
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