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addition to tax for the years in issue. Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980).
To reflect the foregoing,
Decision will be entered for
respondent as to the deficiencies
and additions to tax under section
6654 for 2000 and 2001 and for
petitioner as to the additions to
tax under section 6651 for 2000 and
2001.
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Last modified: May 25, 2011