- 606 - Issue 41. Whether IRA Is Liable for the Section 6662(a) Accuracy-Related Penalty for 1989 OPINION In the notice of deficiency for 1989, respondent determined that IRA was liable for an accuracy-related penalty of $175,780 due to negligence or disregard of rules or regulations and a substantial understatement of tax. IRA had the burden of proving that the imposition of the accuracy-related penalty was erroneous. It failed to do so. Therefore, we sustain respondent's determination. Conclusion To reflect our disposition of the issues in controversy and those settled or conceded by the parties, Decisions in all dockets will be entered under Rule 155.Page: Previous 587 588 589 590 591 592 593 594 595 596 597 598 599 600 601 602 603 604 605 606
Last modified: May 25, 2011