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accuracy-related penalty under section 6662 is appropriate.
Nothing in the record indicates petitioner acted with reasonable
cause and in good faith. The Court holds that the record
supports respondent’s determination that petitioner is liable for
the accuracy-related penalty.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011