- 9 - and do not meet the strict substantiation requirements of section 274(d). We hold that the record supports respondent’s determination of negligence in this case. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing and the concession by respondent, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011