- 13 -
working relationship, but he did not explain how this is relevant
to whether he is liable for the accuracy-related penalty for the
years in issue.
We conclude that petitioner is liable for the accuracy-
related penalty under section 6662(a) for 1996 and 1997.
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011