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section 6653(b)(1) and (2) additions to tax for 1982 through 1985
and section 6653(b)(1)(A) and (B) additions to tax for 1986 and
1987.
We have considered the remaining arguments of both parties
for results contrary to those expressed herein and, to the extent
not discussed above, find those arguments to be irrelevant, moot,
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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