- 8 - to penalties but not to the underlying tax. United States v. Boyle, 469 U.S. 241, 252 (1985). We conclude that the dividend income petitioner received on her mutual fund investment does not qualify as nontaxable interest income under section 871(h). For consistency with the rate of tax as applied in respondent's notice of deficiency, we -- at respondent's request -- sustain respondent's imposition of the 20-percent withholding tax rate on petitioner's dividend income. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011