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income tax return, particularly in view of Roger G. Cotner's
background, leads us to conclude that respondent's imposition of
the accuracy-related penalty is appropriate. Accordingly,
petitioners are liable for the accuracy-related penalty under
section 6662(a) for the year 1990.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011