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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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Last modified: May 25, 2011