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In light of the Court’s holdings that the income in issue is
not attributable to petitioner, and petitioner was not Mr.
Fullen’s common law wife, the Court holds further that petitioner
is not liable for accuracy-related penalties under section
6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: May 25, 2011