Priscilla B. Badger - Page 7

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          statutorily mandated by section 6511(b)(2)(B).  We have                     
          considered petitioner's arguments and find them unpersuasive.               
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                              petitioner as to the                                    
                              deficiency                                              
                                             and additions to tax, and                
                                             petitioner is not entitled to            
          .                                  credit or refund of                      
                                             overpayment.                             






























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