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the accuracy-related penalty under section 6662(a) that is
attributable to petitioner’s underpayment for that year.17
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing,
Decision will be entered under
Rule 155.
17The amount of the accuracy-related penalty under sec.
6662(a) for which petitioner is liable is an amount that is in
excess of the amount of such penalty determined in the notice and
is to be determined under Rule 155. See supra note 10.
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