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related penalty is inapplicable to the taxes and penalties
imposed on one-half of petitioner’s 1993 IRA distributions.
In reaching our holdings herein, we have considered all
arguments made by the parties, and, to the extent not discussed
above, we find those arguments to be irrelevant or without merit.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
10(...continued)
the reasonable basis standard. Sec. 1.6662-3(b)(3), Income Tax
Regs., as amended by T.D. 8790, 1998-50 I.R.B. 4. Among the
authorities set forth in sec. 1.6662-4(d)(3)(iii), Income Tax
Regs., are private letter rulings issued after Oct. 31, 1976.
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