- 14 -
under section 6673. We therefore impose on him under that
section a penalty of $15,000.
VI. Conclusion
We shall enter decision for respondent reflecting (1) the
deficiency in tax determined by respondent, (2) the increased
addition to tax asserted by respondent under section 6651(a)(1),
(3) respondent’s concession of the addition to tax determined
under section 6651(a)(2), (4) the addition to tax
determined by respondent under section 6654, and (5) the penalty
we imposed under section 6673(a)(1).
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011