- 19 - For the 1991 taxable year, we have held that petitioner did not receive a constructive dividend. Therefore, petitioner is not liable for the section 6662(a) accuracy-related penalty for 1991. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011