Jimmy A. Prince - Page 14

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          acted with reasonable cause or in good faith with respect to the            
          items underlying the accuracy-related penalties.  We sustain                
          respondent’s determination as to the addition to tax and the                
          accuracy-related penalties (to the extent that the parties                  
          computation(s) under Rule 155 establishes that petitioner                   
          understated his tax for each of the subject years by the greater            
          of 10 percent of the tax required to be shown on the return or              
               All arguments made by the parties and not discussed herein             
          have been rejected as meritless.  To reflect concessions,                   

                                                       Decision will be               
                                                  entered under Rule 155.             

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Last modified: May 25, 2011