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from the base on which the section 6651(a)(2) addition is
imposed.
We hold that the estate is liable for the additions to tax
at issue herein. We have considered all arguments made by the
estate for a contrary holding, and, to the extent not discussed
above, find them to be irrelevant or without merit. To reflect
respondent's concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011