- 16 - purpose of avoiding his Federal tax obligations. We hold that petitioner is liable for the section 6663 civil fraud penalties as determined by respondent. To reflect the foregoing, An appropriate order will be issued granting respondent’s motion to dismiss, and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011