Gainer v. Commissioner of Internal Revenue

Opinion by Judge Boochever BOOCHEVER, Circuit Judge: The Commissioner of Internal Revenue (Commissioner) appeals from the Tax Court's decision sustaining the income tax deficiency against John B. Gainer (Gainer) but declining to impose an addition to tax pursuant to section 6659 of the Internal Revenue Code. 26 U.S.C. § 6659(a).1 We affirm.