- 10 - We must determine whether petitioners acted with reasonable cause and in good faith within the meaning of section 6664(c)(1) and the regulations thereunder when they reported in Schedule C of their 1999 joint return only $1,892, and not $21,891.95, as the nonemployee compensation that Mr. Larson received from Windermere during 1999. Petitioners contend that they did. In support of that contention, petitioners point out that, because of the alignment error in Form 1099 that Windermere issued to Mr. Larson for the year at issue, it was not readily apparent from reviewing that form that the amount of nonemployee compensation reported therein was $21,891.95, and petitioners assumed that the amount of such compensation reported in that form was $1,891.95. On the instant record, we reject petitioners’ argument that under section 6664(c)(1) and the regulations thereunder the Court should not hold them liable for the accuracy-related penalty under section 6662(a). It is significant that, by reporting only $1,892, instead of $21,891.95, as the amount of nonemployee compensation that Mr. Larson received from Windermere during 1999, petitioners failed to report approximately (1) 91 percent of the total nonemployee compensation that Mr. Larson received from Windermere during that year and (2) 82 percent of the total nonemployee compensation that he received from Windermere and from Data Search during thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011