Court of Appeals for the Ninth Circuit October 9, 1992, 91-35392 (In Re James E. Mitchell and Diane C. Mitchell, Debtors. James E. Mitchell Diane C. Mitchell v. United States)

BEEZER, Circuit Judge:

We consider whether a person, who has some involvement in the filing of an “S corporation” tax return and its related Forms K-l that will result in understatements of income tax, should pay an aiding and abetting penalty for each K-l. 26 U.S.C. § 6701(a), (b) (1988).