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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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Last modified: May 25, 2011