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consolidation, petitioner failed to receive a complete and
accurate Wage and Tax Statement, Form W-2 (wage statement), for
the year 1992. Instead, petitioner received two wage statements
from his employer. One wage statement properly reflects the
wages he received prior to the consolidation of the payroll
processing centers. The other wage statement reflects the wages
of another taxpayer. Petitioner stated that he repeatedly asked
his employer to provide him with a corrected wage statement.
Petitioner and his wife, Rebecca Duncan, timely filed a
joint Federal income tax return for 1992 on April 15, 1993. On
their joint 1992 Federal income tax return, petitioner and Ms.
Duncan reported total wages of $51,335.87. This amount failed to
include all of the wages petitioner received in 1992. Petitioner
alleges that he contacted the Internal Revenue Service (IRS)
prior to filing his 1992 Federal income tax return. Petitioner
asserts that an IRS employee informed him that he should include
on his return a statement indicating that he did not receive an
accurate wage statement. On their 1992 Federal income tax
return, petitioner and Ms. Duncan included such a statement. On
their 1992 Federal income tax return, petitioner and Ms. Duncan
also failed to report interest income in the amount of $5.
On May 10, 1995, respondent sent a letter to petitioner
seeking information about the unreported income. In a letter
dated May 23, 1995, petitioner answered respondent's inquiry and
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