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than making contributions to Buddhist organizations in line with
its stated purpose to financially support the preservation of
Buddhism. Petitioner has never made a charitable contribution to
support Buddhism. Petitioner acted negligently and in disregard
of rules or regulations with regard to its deductions of the
royalty payments to DM. Therefore, it is liable for a section
6662 penalty for each of the years in issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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