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committed fraud, inasmuch as respondent has failed to adduce
evidence showing petitioner's intentional wrongdoing. Accordingly,
we do not sustain respondent's determination with regard to the
section 6651(f) additions to tax for fraud. Because petitioner
concedes that the section 6651(a)(1) additions would be applicable
in this instance, we direct the parties to determine the amount of
those additions in the Rule 155 computations.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011