Judith M. De Shon and Michael J. De Shon - Page 14

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          meaning of section 6662(d)(1)(A)(ii).  Accordingly, we hold that            
          petitioners are not liable for the section 6662(a) accuracy-                
          related penalty.                                                            
                                     Conclusion                                       
               We have considered all of the other arguments made by the              
          parties, and, to the extent that we have not specifically                   
          addressed them, we conclude that they are without merit.                    
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect our disposition of the disputed issues, as well             
          the parties’ concessions,                                                   


                                             Decision will be entered                 
                                        under Rule 155.                               






















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