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section 6662(a) by showing that petitioner has no records and
submitted false documents to the examiner.
Petitioner made no argument that he was not liable for the
addition to tax for failure to file under section 6651(a)(1) for
1998, or for the accuracy-related penalty under section 6662(a)
for 1998, 2000, and 2001. We conclude that petitioner is liable
for the addition to tax for failure to file under section
6651(a)(1) for 1998, and for the accuracy-related penalty under
section 6662(a) for 1998, 2000, and 2001.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011