Everett J. Diers - Page 13

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          or disregard of rules and regulations.                                      
               We have found that petitioner did not report an additional             
          $25,766 of income for 1996.  Nevertheless, respondent concedes              
          that the omission of the Form 1099 income from American was                 
          justified because of petitioner’s reliance on a letter from the             
          attorney who represented him during his settlement with American.           
          Accordingly, no penalty will be imposed on this portion of the              
               We conclude that petitioner is liable for a penalty pursuant           
          to section 6662 for 1996 in the recalculated amount of $1,052.              
          In reaching all of our holdings herein, we have considered all              
          arguments made by the parties, and to the extent not mentioned              
          above, we find them to be irrelevant or without merit.                      
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

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