Jeffrey Ercolino - Page 11

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          of the section 6662(a) negligence penalty is appropriate in                 
          this case.                                                                  
               On balance, we find that petitioner is not liable for the              
          section 6662(a) penalty.                                                    
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent with respect to                
                                        the deficiency and for petitioner             
                                        with respect to the section                   
                                        6662(a) penalty.                              

























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