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stated herein.
(2) Is petitioner liable as a transferee of Radcliffe and
of BOT for the withholding tax that we have sustained against
them? We hold that he is.
(3) Did respondent violate petitioner's right to equal
protection of the law under the Fifth Amendment to the Constitu-
tion by making the withholding tax determinations that we have
sustained against Radcliffe and BOT? We hold that she did not.
(4) Did respondent abuse her discretion by making the
withholding tax determinations that we have sustained against
Radcliffe and BOT? We hold that she did not.
(5) Are Radcliffe and BOT liable for the additions to tax
for failure to file timely required withholding tax returns? We
hold that they are to the extent stated herein.
(6) Are Radcliffe and BOT liable for the additions to tax
for negligence or disregard of rules or regulations? We hold
that they are to the extent stated herein.
(7) Are Radcliffe and BOT liable for the penalties for
failure to make timely deposits of required withholding tax? We
hold that they are to the extent stated herein.
(8) Is petitioner liable as a transferee of Radcliffe and
of BOT for the additions to tax and penalties that we have
sustained against them? We hold that he is.
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