Roydell Campbell - Page 9




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               Loans.  If you borrow money from an employer’s                         
               qualified pension or annuity plan * * * you may have to                
               treat the loan as a distribution.  This means that you                 
               may have to include in income all or part of the amount                
               borrowed. * * *                                                        
               The record demonstrates that petitioner was aware that some            
          or all of each loan was a taxable distribution, yet he declined             
          to include any part of the loans as income.  On the basis of the            
          entire record, we conclude petitioner has not established that              
          the underpayment was due to reasonable cause or that petitioner             
          acted in good faith.  Accordingly, we hold petitioner is liable             
          for the accuracy-related penalty.                                           
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered under Rule 155.3            

















               3    The Rule 155 computation will take into account a Form            
          W-2C, Corrected Wage and Tax Statement, from the City of New                
          York.                                                                       





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