-12-
penalty in this case, we caution petitioner that should he bring
similar arguments before this Court in the future, he is at risk
that the Court is likely to impose such a penalty, up to $25,000.
Accordingly, we sustain respondent’s determination in the
notice of deficiency with respect to the addition to tax under
section 6651(a)(1), as adjusted to reflect the agreed upon tax
liability.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011