Russell W. Coulton - Page 12

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          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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