- 11 - case law in contending that petitioner's employment with Motorola was temporary. On the basis of the record, we hold that petitioners did not comply with the requirements of section 162(a)(2) and are therefore liable for the accuracy-related penalty on the underpayment for the 1994 tax year. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011