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Issue 2. Penalty Under Section 6662(a)
In the answer, respondent determined that for 1989
petitioners were liable for the accuracy-related penalty of
section 6662(a).
On the basis of our holding above, there was no underpayment
of tax due to petitioners' characterization of the disposition of
the Dime Circle property. Accordingly, petitioners are not
liable for the accuracy-related penalty pursuant to section 6662.
To reflect concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011