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6654(e)(2) and is, therefore, not liable for the section 6654
addition to tax.
The Court has considered all other arguments advanced by the
parties, and, to the extent such arguments have not been
specifically addressed, the Court concludes they are without
merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered for
respondent for the deficiency and the
section 6651(a)(1) addition to tax and
for petitioner for the section 6654(a)
addition to tax.
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Last modified: May 25, 2011