- 24 - the $17,516 underpayment, but we hold that respondent abused his discretion in not granting petitioner relief for the balance of the $17,516 underpayment and the related penalty, additions to tax, and interest. Such additional relief is to be granted to petitioner. To reflect the foregoing, Decision will be entered under Rule 155.7 7 Under our holding herein, refunds to petitioner relating to petitioner and John’s underpayment and deficiency may be limited, respectively, under Rev. Proc. 2003-61, sec. 4.04(2), and sec. 6015(g)(3). In the Rule 155 computation, the parties are to resolve how petitioner’s various payments are to be allocated among the underpayment, the deficiency, and the penalty, additions to tax, and interest.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011