- 16 -
reaching our conclusion that the penalty should apply to both
petitioners, we have considered that Mrs. Rifkin operated the
business, dealt with the clients, and likely received and made
payments in connection with the business. Her attempt to
attribute the return inadequacies to her now deceased husband
must fail.
To reflect the foregoing and to account for concessions of
the parties,
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
Last modified: May 25, 2011