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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.
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Last modified: May 25, 2011