- 12 -
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6651(c)(1) is no longer applicable.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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011