- 14 - result in “impermissible stacking”. Zaban v. Commissioner, T.C. Memo. 1997-479. Because petitioner is liable for the fraud penalty on the entire underpayment, Mrs. Said is not liable for the accuracy-related penalty. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011