- 38 -
this case is not an abuse of discretion. Petitioners are liable
for the section 6659 addition to tax at the rate of 30 percent of
the underpayment of tax attributable to the disallowed tax
benefits. Respondent is sustained on this issue.
Decision will be entered
under Rule 155.
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Last modified: May 25, 2011