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the section 6662(a) accuracy-related penalty should not be imposed
for either year under consideration.
We have considered all arguments made by the parties for
contrary holdings, and, to the extent not discussed, find them to
be without merit.
To reflect the foregoing,
Decision will be entered
for respondent with respect
to the deficiencies and for
petitioners with respect to
the addition to tax under
section 6662(a).
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