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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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Last modified: May 25, 2011