Michael C. Dodge - Page 4




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          (9th Cir. 1991); United States v. Kerwin, 945 F.2d 91, 92 (5th              
          Cir. 1999) (per curiam); Wheeler v. Commissioner, 127 T.C. 200,             
          208 (2006) (“The Paperwork Reduction Act is not a defense to the            
          addition to tax under section 6651(a)(1), nor does it create a              
          loophole in the Code”).                                                     
               We conclude that petitioner is liable for the section                  
          6651(a)(1) and section 6654(a) additions to tax.  See also Rule             
          142(a).                                                                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          



























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