Ivan Andre Zaal - Page 7

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          item by petitioner.  Sec. 6662(d)(2)(B)(ii).  Here, petitioner              
          neither disclosed the omitted $113,081 renewal commissions on his           
          tax return nor did he have a reasonable basis for their omission.           
               We hold that petitioner is liable for the penalty under                
          section 6662(a) for 1994.                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          
































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