- 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
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