- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011