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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.
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