Joseph A. Loftus - Page 15

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          written advice on which he relied and to which he can attribute             
          his failure to pay timely his tax liabilities for 1996 and 1997.            
                                      Conclusion                                      
               The Court has considered all of petitioner’s contentions,              
          arguments, and requests, and to the extent they were not                    
          discussed, the Court concludes that they are moot, irrelevant, or           
          without merit.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   

                                                  Decision will be entered            
          for respondent.                                                             



























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