-52-
6653(a)(1) for fiscal year 1989, the addition to tax applies only
if there is an underpayment of tax as defined in section 6653(c).
As discussed above, petitioner is not liable for the
accumulated earnings tax. The only possible underpayment relates
to the environmental tax under section 59A. Petitioner has
presented no evidence or argument as to whether any underpayment
of the environmental tax was reasonable. Thus, if the Rule 155
computation shows that petitioner underpaid the environmental
tax, all of that underpayment is due to negligence.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
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