John J. Zanath - Page 13




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          liable for the section 6651(a)(2) addition to tax, section                  
          6651(c)(1) is no longer applicable.                                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             An order will be entered                 
                                        dismissing this case for lack of              
                                        jurisdiction as to the section                
                                        6654(a) addition to tax, and                  
                                        decision will be entered for                  
                                        petitioner as to the section                  
                                        6651(a)(1) addition to tax and for            
                                        respondent as to the deficiency and           
                                        the increased section 6651(a)(2)              
                                        addition to tax.                              






















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Last modified: May 25, 2011