Charlotte Marie Scott - Page 12

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          Commissioner, 59 T.C. 456, 458 (1972).  We have applied the                 
          relevant statute, and we have concluded that respondent correctly           
          applied the law in this case.  Respondent’s imposition of the               
          additional tax is sustained.                                                
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be entered            
                                             for respondent.                          
































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