Subhendu Das - Page 11

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               At trial and on brief, petitioner did not address the                  
          section 6662(a) penalty.  Petitioner prepared the joint returns             
          for the years at issue.  We find that petitioner is liable for              
          the accuracy-related penalty for failing to report a capital gain           
          and for improperly claiming expenses that are not allowable.                
          Accordingly, respondent is sustained on this issue.                         
               To reflect the foregoing,                                              



                                             Decisions will be entered                
                                         under Rule 155.                              



























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Last modified: May 25, 2011