James B. Clark - Page 11

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         section 6662(a) by showing that petitioner has no records and                
         submitted false documents to the examiner.                                   
              Petitioner made no argument that he was not liable for the              
         addition to tax for failure to file under section 6651(a)(1) for             
         1998, or for the accuracy-related penalty under section 6662(a)              
         for 1998, 2000, and 2001.  We conclude that petitioner is liable             
         for the addition to tax for failure to file under section                    
         6651(a)(1) for 1998, and for the accuracy-related penalty under              
         section 6662(a) for 1998, 2000, and 2001.                                    
              To reflect the foregoing,                                               

                                                       Decision will be               
                                                 entered for respondent.              
























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