Sharon Purcell DiLeonardo - Page 30




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               We hold for petitioner.                                                
               To reflect the foregoing,9                                             


                                                       Decision will be               
                                                  entered for petitioner.             





















          9    From the notice of deficiency and petitioner’s 1993 income             
          tax return, it is apparent that, as a result of our holding for             
          petitioner on the disputed issue, she does not have a 1993                  
          Federal income tax liability.  As a result, under paragraph (1)             
          and the last sentence of sec. 6651(a), the addition to tax                  
          resulting from petitioner’s conceded failure to timely file her             
          1993 tax return is zero.                                                    












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