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$5,000, the underpayment of tax required to be shown on their
1997 return is not a substantial understatement of income tax.
Consequently, they are not liable for the accuracy-related
penalty imposed by section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Based on the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011