9
In view of the foregoing, we sustain respondent’s additions
to tax under sections 6651(a)(1) and 6654(a)(2), respectively.
Reviewed and adopted as the report of the Small
Tax Case Division.
Decision will be entered
for respondent as to the
deficiency, and additions to
tax under sections 6651(a)(1)
and 6654(a)(2), and for
petitioner as to the addition
to tax under section
6651(a)(2).
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