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Although petitioners may perceive the accuracy-related
penalty under section 6662(a) to be unfair, the applicable
statutory language is clear and unambiguous, and this Court has
no power to expand the explicit terminology of the statute.
Donigan v. Commissioner, 68 T.C. 632, 636 (1977). The Court must
apply the law as written. Accordingly, respondent is sustained
on the imposition of the accuracy-related penalty under section
6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011