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Petitioner filed his 2002 and 2003 income tax returns and
reported all of his income from wages. At the time of filing,
petitioner was new to this country and unfamiliar with the U.S.
tax system, let alone the intricacies of the tax convention
between the United States and Belgium. Even respondent had
difficulty applying the treaty to petitioner’s situation, as
evidenced by the necessity of issuing a supplement to his
original notice of deficiency. We hold that petitioner is not
liable for the accuracy-related penalties under section 6662.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007