Reza and Connie M. Rezazadeh - Page 27

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          failed to report on the face page of their tax return the actual            
          amount of Social Security benefits they received that year.                 
          Based on their reported income and expenses, petitioners properly           
          calculated that none of the Social Security benefits received in            
          1992 was taxable.  The worksheet, however, is not filed and is              
          not part of the tax return.  The Court does not find that                   
          petitioners' failure to report on the face of their return the              
          amount of Social Security benefits received constitutes                     
          negligence or represents a disregard of rules or regulations.               
          Accordingly, with respect to the penalties for 1992, petitioners            
          are sustained.                                                              



                                                  Decisions will be entered           
                                             under Rule 155.                          




















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