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petitioner is liable for the excise tax imposed by section 4980A
for 1990.20
V.Conclusion
In order to give effect to our disposition of the disputed
issues, as well as the parties' concessions,21
Decision will be entered
under Rule 155.
20 See supra note 15 and accompanying text. Further, we
note that petitioner is not entitled to the offset provided by
sec. 4980A(b) in view of our conclusion, supra, that petitioners
are not liable for the 10-percent additional tax under sec.
72(t).
21 See supra note 6.
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