- 8 -
interest herein. See Commissioner v. McCoy, 484 U.S. 3, 7
(1987); 508 Clinton Street Corp. v. Commissioner, 89 T.C. 352,
354 (1987).
Decision will be entered for
respondent with respect to the
deficiency, including the
additional tax under sec. 72(t),
and decision will be entered for
petitioners with respect to the
penalty under sec. 6662(a).
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Last modified: May 25, 2011