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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
underpayment.
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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Last modified: May 25, 2011