- 7 -
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.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011