Travis and Jayne Sanderson - Page 11

                                       - 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