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4(b)(4), Income Tax Regs. (cross-referencing sec. 1.6664-2(c),
Income Tax Regs.). Accordingly, if the recomputed deficiencies
satisfy the statutory percentage or amount, petitioners will be
liable for such penalty.
All other contentions raised by the parties are either
irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
pursuant to Rule 155.
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Last modified: May 25, 2011