- 20 - Petitioner knew or should have known that the same treatment or characteristic of the $12,500 debt applied; yet, he erroneously attributed it to a purported trade or business activity. The Court, therefore, sustains respondent on the section 6662(a) penalty. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011