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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
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011