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petitioner acted with reasonable cause and good faith as to the
underpayment resulting from the additional tax in issue.
Accordingly, we hold that petitioner is not liable for the
accuracy-related penalty pursuant to section 6662(a).
We have considered all of petitioner’s contentions,
arguments and requests that are not discussed herein, and
conclude that they are without merit or irrelevant.
To reflect the foregoing,
An appropriate decision
will be entered.
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Last modified: May 25, 2011