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Respondent also determined that Mr. Perry is liable for
the accuracy-related penalty prescribed by section 6662
with respect to his 1989, 1990, and 1991 returns. Because
we have not sustained respondent's determination of tax
deficiencies in petitioners' or Mr. Perry's income tax for
the years in issue, there is no basis for the imposition of
the additions to tax and penalties determined by respondent
in the notice of deficiency.
In light of the foregoing,
Decision will be entered
for petitioners.
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