Joe M. and Patricia M. Brown - Page 28

                                       - 28 -                                         
          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.                                                        







Page:  Previous  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  

Last modified: May 25, 2011