- 19 -
that petitioner is not liable for the addition to tax for
negligence for either taxable year.
With respect to the delinquency addition, petitioner has
failed to offer evidence that would relieve her of that
obligation, and, to the extent that the Rule 155 computation
results in any income tax deficiency due from petitioner, she
will be liable for the section 6651(a)(1) delinquency addition to
tax.
To account for concessions of the parties and to reflect the
foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011