Jon D. Dezagottis - Page 10




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                    ordinary care and prudence in this case.  Accordingly, petitioner                                                                                      
                    is liable for the addition to tax under section 6651(a)(1).                                                                                            
                    Respondent is sustained on this issue.                                                                                                                 
                              Reviewed and adopted as the report of the Small Tax Case                                                                                     
                    Division.                                                                                                                                              
                                                                                                    Decision will be entered                                               
                                                                                          under Rule 155.                                                                  



































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