Kevin and Deborah Keith - Page 8




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          be shown on petitioners’ 2002 return is a substantial                       
          understatement of income tax.  Considering the foregoing, the               
          understatement will be far less than the amount required for the            
          imposition of the penalty.  See sec. 6662(d).  Respondent’s                 
          imposition of the section 6662(a) accuracy-related penalty is               
          rejected.                                                                   
               To reflect the foregoing,                                              

                                        Decision will be entered                      
                                   under Rule 155.                                    






























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Last modified: March 27, 2008