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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
$5,000).
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