- 32 -
Forms 1042 and 1042S for the years in issue. Accordingly, we
sustain respondent’s determination that petitioner is liable for
the section 6651(a)(1) addition to tax for each of the years in
issue, to the extent consistent with this opinion.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32
Last modified: March 27, 2008