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4. Respondent’s Request To Impose a Section 6662(a) Penalty
At trial, respondent also requested leave to impose a
section 6662(a) penalty upon the ground that petitioner failed to
maintain adequate records to substantiate the deductions claimed
on the unprocessed amended return. See sec. 1.6662-3(b), Income
Tax Regs. Again, ignoring the technical and procedural
infirmities surrounding respondent’s request, given the manner in
which the amended return has been treated, imposition of the
penalty is not appropriate. Respondent’s request is denied.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011