-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011