- 19 - Consequently, we do not sustain respondent’s determination that petitioner is liable for an addition to tax pursuant to section 6651(a)(1). Decision will be entered for respondent with respect to the deficiency and for petitioner with respect to the addition to tax under section 6651(a)(1).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