Frank Franklin - Page 11

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          intentionally disregarded rules or regulations in failing to                
          report the $1,193 in Metropolitan Life Insurance Co. payments.              
          Moreover, there was no underpayment of tax with respect to this             
          item because the tax thereon was withheld at the source and                 
          presumably remitted by the payor to respondent.  Sec. 6664(a).              
          The Court, therefore, sustains petitioner on the section 6662(a)            
          penalty with respect to the $1,193 income item.                             
               Reviewed and adopted as the report of the Small Tax Case               

          Decision will be entered                                                    
          under Rule 155.                                                             

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